Privacy Policy

BoskovichFarms.com

Last updated: June 11, 2021

At Boskovich, we care deeply about privacy. We believe in transparency, and we are committed to our privacy practices, including how we treat your personal information. We know you care about your privacy too, so we provide settings that allow you to choose how certain information is used by Boskovich. This policy explains our privacy practices for BoskovichFarms.com (the “Site”) and other services provided by Boskovich Fresh Food Group, Inc. or Boskovich Farms, Inc., depending on your location (“Boskovich,” together with “we,” “us,” and “our”).  We may refer to the Site and our other services as the “Services.”  Boskovich Farms, Inc. is the data controller and is responsible for your personal information. This policy does not apply to the practices of third parties (including other members who sell using the Services or API users) who may also collect or receive data in connection with your use of the Services.

1. Our Privacy Policy

We process your personal information to run our business and provide our users with the Services. By accepting our Terms of Use (and in some jurisdictions, by acknowledging this policy), you confirm that you have read and understand this policy, including how and why we use your information. If you don’t want us to collect or process your personal information in the ways described in this policy, you should not use the Services. We are not responsible for the content or the privacy policies or practices of any third-party websites and apps.

Boskovich’s Terms of Use require all account owners to be at least 18 years of age. Minors under 18 years of age and at least 13 years of age are permitted to use Boskovich’s Services only if they have permission and direct supervision by the owner of the account. Children under age 13 are not permitted to use the Services. You are responsible for any and all account activity conducted by a minor on your account. We do not knowingly “sell,” as that term is defined under applicable law, including the California Consumer Privacy Act, the personal information of minors.

By using the Services, you acknowledge that Boskovich will use your information in the United States and any other country where Boskovich operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to those countries to which we are permitted by law to transfer personal information as more fully described in the “Transfers” Section of this policy.

2. Information Collected or Received

In the course of providing our Services, we collect or receive your personal information in a few different ways. We obtain the categories of personal information listed below from the following sources: directly from you, for example, from forms you complete or during registration; indirectly from you based on your activity and interaction with our Services, or from the device or browser you use to access the Services; from our vendors and suppliers that help provide Boskovich services you may interact with (such as, for example, customer support), and from our third party advertising and marketing partners. Often, you choose what information to provide, but sometimes we require certain information to provide you the Services. Boskovich uses the personal information it receives and collects in accordance with the purposes described in this policy.

In order to use the Services, will need to submit a valid email address. If you register, you will need to submit a name associated with your account. You may modify that name through your account settings. You need to provide this information to enable us to provide you with the Services.

Profile: From time to time, we may also ask you about certain demographic information, such as your race, ethnicity, sexual orientation, or gender identity, in relation to specific marketing and advocacy projects and campaigns. Providing this demographic information is entirely voluntary and at the time we ask we will also seek your consent to use it.

Automated Information: Boskovich automatically receives and records information from your browser or your mobile device when you visit the Site or use certain features of the Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. Boskovich may also receive similar information (like, for example, IP addresses and actions taken on the device) provided by a connected Internet of Things device such as a voice-activated assistant or Smart TV.  We may combine this information from your browser or your mobile device with other information that we or our advertising or marketing partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for members and visitors, and to provide advertising, including across your devices, and a more personalized experience for members and visitors.

We also automatically collect device-specific information when you install, access, or use our Services. This information can include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers. For more information about these online tools and how we use them, see our Cookies & Similar Technologies Policy and “Information Uses, Sharing, & Disclosure” Section below.

Data from Boskovich Vendors and Suppliers: We also receive information from our vendors and suppliers about you. This information can include customer service interactions.

Data from Advertising and Marketing Partners: As described below, Boskovich receives information from our advertising and marketing partners about you. This information can include attribution information via cookies and UTM tags in URLs to determine where a visit to Boskovich comes from, responses to marketing emails and advertisements, responses to offers, and audience information from partners who you have given consent to share that information with us.

Location Information: We collect information about your use of the Services for advertising, for analytics, to serve content, and to protect the Services. This can include your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device). When you use the Site, you can choose to share your geolocation details with Boskovich in order to use functions like our local marketplace, maps, and for in-person sales (although you don’t need to share these details). You can choose to publish your location when you sell on Boskovich.

We obtain location information you provide in your profile or your IP address. With your consent, we may also determine location by using other information from your device, such as precise location information from GPS or information about wireless networks or cell towers near your mobile device. We use and store information about your location to provide features and to improve and customize the Services, for example, for Boskovich’s internal analytics and performance monitoring; localization, regional requirements, and policies for the Services; for local content, search results, and recommendations; for shipping and mapping services; and (using non-precise location information) marketing. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on the Site or on your mobile device. Certain non-precise location services, such as for security and localized policies based on your IP address or submitted address, are critical for the Site to function. We will only share your geolocation details with third parties (like our mapping, payments, or, to the extent applicable, advertising providers) in order to provide you with the Services.

Analytics Information: We use data analytics software to ensure Site functionality and to improve the Services. This software records information such as how often you use the Site, what happens within the Site, aggregated usage, performance data, app errors and debugging information. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application. For more information, see Boskovich’s Cookies and Similar Technologies Policy and Disclosures.

Information from Third Parties: Some members or visitors may choose to connect to Boskovich or register an Boskovich account using an external third-party application, such as Facebook. Connecting your Boskovich account to third-party applications or services is optional. If you choose to connect your account to a third-party application, it is subject to your agreements with that third party (like their Terms of Use and privacy notices), and Boskovich can receive information from that application. We may also collect public information in order to connect with you, such as when we communicate with you over social media. We may use that information as part of providing the Services to you. You can also choose to share some of your activity on Boskovich on certain social media networks which are connected to your Boskovich account, and you can revoke your permission anytime in your account settings. Certain third-party applications that you use to create or sign in to your account may provide you with the option to discontinue receiving messages from us or allows you to forward those messages to another email address. If we are unable to send you critical messages about your account, we may suspend or terminate your account.

3. Messages from Boskovich

On occasion, Boskovich will need to contact you. Primarily, these messages are delivered by email or by push notifications for a variety of reasons, including marketing, transactions, advocacy, and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications via email by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. Every account is required to keep a valid email address on file to receive messages. Boskovich may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent where required by applicable law, Boskovich may send you an SMS (or similar) message, or reach out to you by telephone, in order to provide you with customer support, for research or feedback, or to provide you with information about products and features that you may find of interest. You can update your contact preferences in your account settings.

4. Information Uses, Sharing, & Disclosure

We respect your privacy. Boskovich will not disclose your name, email address, or other personal information to third parties without your consent, except as specified in this policy.

You can control your privacy settings through the opt-out buttons in your account settings privacy tab, and the Privacy Settings link in the footer of most site pages and our homepage. Please note that some changes to your privacy settings may take a few days to take effect. We or our sellers may advertise our Services or our sellers’ products through a variety of different mediums and rely on your consent to do so off-site.

Legal Bases

When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:

Necessary to perform the contractual obligations in our Terms of Use and in order to provide the Services to you;

 You have consented to the processing, which you can revoke at any time;

• Necessary to comply with a legal or regulatory obligation, a court order, or to exercise or defend any impending or asserted legal claims;
• Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
• You have expressly made the information public;
• Necessary in the public interest, such as to prevent crime; and
• Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).

We principally rely on consent (which can be withdrawn at anytime) (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes.

We rely on consent for targeted online and offline marketing including through tools like XXX. We or our sellers may advertise our Services or our sellers’ products through a variety of different mediums and rely on your consent to do so off-site. As part of this, we may work with advertising partners such as Google, and other partners. These partners have their own privacy policies and consent mechanisms for their customers, in addition to Boskovich’s controls.  You may see the privacy policies and privacy choices for these partners, and the information you share with them.

Boskovich may also use first party data (e.g. your prior shopping and browsing patterns on our Site), and may combine it with other data collected from you, such as your location, or publicly available information, to permit us to create targeted audiences based on your known or inferred demographic and/or interests to provide you with more relevant and useful advertising on our site, in our direct marketing channels (like email), or with our off site marketing partners, like Google, subject to their terms and privacy notice you agreed to with such partners .

Our Legitimate Interests

Where we process your information on the basis of legitimate interests, we do so as follows:

Providing and Improving our Services: We use your information to improve and customize our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services.

Providing Marketing Communications: We rely on our legitimate interest to send you marketing messages (where permitted independent of consent) and for Boskovich’s advertising programs (including Boskovich’s on-site advertising and marketing).

Keeping our Services Safe and Secure: We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to Boskovich’s systems, or those of our users or our partners. This includes enhancing protection against spam, harassment, intellectual property infringement, crime, and security risks of all kinds.

Site Customization: We may learn about the types of products that you’re interested in from your browsing and purchasing behavior on (and off) the Site and use such information to suggest potential purchases as a result. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases.

Legal and Safety: Boskovich may also retain, preserve, or release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against impending or asserted legal claims, including to collect a debt, or a material violation of our policies (including our Intellectual Property Policy); to comply with a subpoena, court order, legal process, regulation, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our rights or property, or violations of Boskovich’s Terms of Use. For example, if permitted due to the forgoing circumstances, your information may be shared with tax authorities or other governmental agencies. In the cases set out above, our use of your information may be necessary for the purposes of our or a third party’s legitimate interest in keeping our Services secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Such use may also be necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims or to facilitate the collection of taxes and prevention of tax fraud. It may also be necessary in the public interest (such as to prevent crime) or to protect vital interests (in rare cases where we may need to share information to prevent loss of life or personal injury).

If Boskovich receives a lawful, verified request for records or information in one of the limited circumstances described in the previous paragraph, Boskovich may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, company/trading name and, where appropriate, bank account and transaction details.

We may work with advertising partners such as Mailchimp, Facebook, or Google, and we may use analytics aggregated from usage information including, for example, search keywords, favorites, browsing history, and purchase history.

Aggregated Information: Boskovich may share demographic information with business partners, but it will be aggregated and de-personalized so that personal information is not revealed.

Service Providers: Boskovich also needs to engage third-party companies and individuals (such as research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to Boskovich not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.

Third Parties: Third-party plug-ins may also collect information about your use of the Site. For example, when you load a page on Boskovich that has a social plug-in from a third-party site or service, such as a “Like” or “Send” button, you are also loading content from that third-party site. That site may request cookies directly from your browser. These interactions are subject to the privacy policy of the third-party site. In addition, certain cookies and other similar technologies on the Site are used by third parties for targeted online marketing and other purposes. These technologies allow a partner to recognize your computer or mobile device each time you use the Services. Please be aware that when you use third-party sites or services, their own terms and privacy policies will govern your use of those sites or services. Boskovich chooses and manages these third-party technologies placed on its Site. However, these are third-party technologies, and they are subject to that third party’s privacy policy. We rely on your consent to drop and read these cookies when not technically necessary or when not required based on another purpose such as legitimate interest.

This policy does not apply to the practices of third parties that Boskovich does not own or control or individuals that Boskovich does not employ or manage, except as otherwise provided for in the Terms or as required by law. If you provide your information to such third parties in connection with your use of the Services, different practices may apply to the use or disclosure of the information that you provide to them. While Boskovich requires these third parties to follow Boskovich’s privacy and security requirements, Boskovich does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, Boskovich is not responsible for the privacy or security practices of these sellers, API users, or other websites on the internet, even those linked to or from the Services. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

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

Email Marketing

We may use Your Personal Data to 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. We may use Email Marketing Service Providers to manage and send emails to You.

Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Behavioral Remarketing

Boskovich uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

• Measure and analyze traffic and browsing activity on Our Service
• Show advertisements for our products and/or services to You on third-party websites or apps
• Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

Google Ads (AdWords)

Google Ads (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

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter’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 Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266

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

5. Transfers

By using our Services, you understand that Boskovich Fresh Food Group, Inc. may share some of the information it gathers with other Boskovich affiliates for purposes described in this privacy policy.

6. Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received, for example encryption is used for certain information (such as credit card numbers) using TLS (transport layer security). Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about the security of your personal information, you can contact us at XXXXX@Boskovich.com.

7. Retention

Boskovich will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active, or as needed to provide the Services to you. Boskovich will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.

8. Your Rights & Choices

Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, Boskovich gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your Boskovich account information or request to permanently delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.

• Right to Access & Portability: You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used..
• Right to Correction: You have the right to request that we rectify inaccurate information about you.
• Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
• Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Boskovich.
• Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
• Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect 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. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: No.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

Publicly available information from government records

Deidentified or aggregated consumer information

Information excluded from the CCPA’s scope, such as:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

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

Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service.

Indirectly from You. For example, from observing Your activity on our Service.

Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.

From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to deliver targeted advertising to You, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

To operate our Service and provide You with our Service.

To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.

To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to You when collecting Your personal information or as otherwise set forth in the CCPA.

For internal administrative and auditing purposes.

To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

Category A: Identifiers

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category F: Internet or other similar network activity

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

Service Providers

Our affiliates

Our business partners

Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

• The categories of personal information We collected about You
• The categories of sources for the personal information We collected about You
• Our business or commercial purpose for collecting or selling that personal information
• The categories of third parties with whom We share that personal information
• The specific pieces of personal information We collected about You
• If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
• The categories of personal information categories sold
• The categories of personal information categories disclosed

The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.

The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:

• Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:

• Denying goods or services to You
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to You
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

By email: ContactPrivacyPolicy@boskovichfarms.com

By visiting this page on our website: boskovichfarms.com/contact

By phone number: XXX.XXX.XXXX

By mail: PO Box 1352, Oxnard, CA 93032

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative

Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

Verify Your identity or authority to make the request

And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

The EDAA’s opt-out platform http://www.youronlinechoices.com/

The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices

“Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Shine the Light

California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes.  Boskovich does not share any personal information to third parties for their own direct marketing purposes. If you have questions about these practices, you can contact us through one of the channels listed in the “Contact” Section below.

Accessibility

If you have a disability and would like to access this policy in an alternative format, please contact us using one of the channels listed in the “Contact” section below.

9. Privacy Policy Changes

We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the Site.  We encourage you to check back regularly and review any updates.

10. Contact

If you have any questions:

Contact Boskovich

Send an email to Boskovich’s Data Protection Officer at XXXXX@BoskovichFarms.com.

Write to us at one of the following address:

Boskovich Fresh Food Group, Inc.

PO Box 1352, Oxnard, CA 93032

Copyright © 2021 Boskovich Fresh Food Group, Inc.