Batory Foods’ California Privacy Rights Act
Effective: January 1, 2023
Last Updated/Reviewed on: June 28, 2023
The California Privacy Rights Act (“CPRA”) provides You with certain rights:
- Knowledge of information that the Company has collected about You;
- Knowledge of information that the Company has sold, shared, or disclosed to a third party;
- Deletion of information collected;
- Correction of information collected;
- Not to be discriminated or retaliated against for exercising rights under the CPRA.
Where The Company Got Your Information From
Batory Foods (the “Company” or “Batory”) may have collected information about You from the following sources: 1) You; 2) prior employers, references, recruiters, job-related social media platforms; 3) third-party sources of demographic information; 4) third-party companies, such as background check companies, drug testing facilities, and customer listing/third party marketing parties; 5) claim administrators and investigators; and 6) unions (only for union employees).
Depending on the Company’s interactions with You, the Company may or may not have collected information about You from any of the sources identified above.
The Information The Company Has Collected
The Company has or may have collected the following Personal Information about You:
- Identifiers, such as name, alias, government-issued identifier (e.g., Social Security number), and unique identifiers (e.g., employee ID);
- Personal information such as:
- real name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, passport number, federal identification authorizing work in the United States, access and/or passcodes, insurance policy number, education, employment, and employment history,
- bank account number, credit card number, debit card number,
- Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account bank account number, other financial information, medical information, or health insurance information,
- Your racial or ethnic origin, religious or philosophical beliefs, an employee’s union membership,
- Your genetic information, health, sex life or sexual orientation, biometric information for the purpose of uniquely identifying You;
- Characteristics of protected classifications under California or federal law, such as race (including traits historically associated with race), religious creed, color, national origin, ancestry, physical or mental disability, medical condition, genetic information, marital status, sex, gender, gender identity or expression, age (40 and older), sexual orientation, military or veteran status, or reproductive health decisionmaking, or any other classifications protected by federal or California law;
- Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements [or purchases from Company]) or other purchasing or consuming histories or tendencies;
- Internet or network activity information, such as browsing history and interactions with our online systems and websites and any personal information that you provide while accessing the Company’s computer systems, such as personal credit card information and passwords;
- Your precise geolocation data, such as device location from usage of the Company’s devices;
- Biometric information related to access to the Company’s secured access points;
- Audio, electronic, visual, thermal, olfactory, and similar information;
- Professional or employment-related information, including but not limited work history and prior employer;
- Non-public education information;
- Contents of mail, email and text messages, unless the Company is the intended recipient of the communication; and
- Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
The Company does not sell or share any Personal Information it collects to third parties.
The Company does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.
Depending on the Company’s interactions with You, the Company may or may not have collected all of the Personal Information about You identified above.
How The Company Has Used Your Personal Information
The Company may have used Personal Information collected about You for any of the following reasons:
- To operate, manage, and maintain our business, including but not limited to, encouraging customers to purchase our products and use our services, performing services or providing goods;
- For hiring, retention, and employment purposes, including, but not limited to administering employment benefits and providing access to those benefits to employees, their dependents, or beneficiaries;
- To uniquely identify an employee (e.g. using biometric information to identify an employee);
- To ensure the physical safety of natural persons;
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity or confidentiality of stored or transmitted personal information.
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the Company and to prosecute those responsible for those actions;
- Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of Your current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;
- To verify or maintain the quality of safety of product, service, or device that is owned, manufactured, manufactured for, or controlled by the Company and to improve, upgrade, or enhance those services or devices.
- To otherwise accomplish our business purposes and objectives, including, for example:
- Emergency services;
- Conducting research, analytics, and data analysis;
- Maintaining our facilities and infrastructure;
- Quality and safety assurance measures;
- Conducting risk and security controls and monitoring;
- Protecting confidential and trade secret information;
- Detecting and preventing fraud;
- Performing identity verification;
- Performing accounting, audit, and other internal functions, such as internal investigations;
- Complying with the law, legal process, and internal policies;
- Maintaining records;
- Claims processing;
- Responding to legal requests for information and subpoenas; and
- Exercising and defending legal claims;
- To collect or process Sensitive Personal Information for any other reason that is not for the purpose of inferring characteristics about You.
- Any other purposes authorized by applicable federal, state, or local law.
Depending on the Company’s interactions with You, the Company may or may not use Personal Information about You for each of the above purposes.
The Company does not use Your Personal Information for purposes other than those identified above.
Disclosing of Personal Information To Third Parties.
The Company has or may have disclosed the following Personal Information about You to third parties:
- Identifiers, such as name, alias, government-issued identifier (e.g., Social Security number), and unique identifiers (e.g., employee ID);
- Personal information, such as:
- real name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, passport number, federal identification authorizing work in the United States, access and/or passcodes, insurance policy number, education, employment, and employment history,
- bank account number, credit card number, debit card number,
- an employee’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account bank account number, other financial information, medical information, or health insurance information,
- Your racial or ethnic origin, religious or philosophical beliefs, an employee’s union membership,
- Your genetic information, an employee’s health, sex life or sexual orientation, biometric information for the purpose of uniquely identifying an employee;
- Characteristics of protected classifications under California or federal law, such as race (including traits historically associated with race), religious creed, color, national origin, ancestry, physical or mental disability, medical condition, genetic information, marital status, sex, gender, gender identity or expression, age (40 and older), sexual orientation, military or veteran status, or reproductive health decisionmaking, or any other classifications protected by federal or California law;
- Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements [or purchases from the Company]) or other purchasing or consuming histories or tendencies;
- Internet or network activity information, such as browsing history and interactions with our online systems and websites and any personal information that You provide while accessing the Company’s computer systems, such as personal credit card information and passwords;
- Precise geolocation data, such as device location from usage of the Company’s devices;
- Biometric information related to access to the Company’s secured access points;
- Audio, electronic, visual, and similar information;
- Professional or employment-related information, including but not limited work history and prior employer;
- Non-public education information;
- Contents of an employee’s mail, email and text messages, unless the Company is the intended recipient of the communication;
- Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics;
The Company has or may have disclosed information about You to the following categories of third parties: 1) government entities, including but not limited to state or federal tax agencies and law enforcement; 2) employment-related third-party companies, including but not limited to, third parties responsible for administering employment benefits; background check companies, drug testing facilities, online human resource depository platforms; operating systems and platforms, online document management systems; payrolls, internet service providers, and third companies for any other employment purpose; 3) customer listing/third party marketing parties; 4) insurance companies; 5) claim administrators and investigators; and 6) unions (only for union employees).
Depending on the Company’s interactions with You, the Company may or may not have shared all of the information identified above about You.
The Company may have disclosed Personal Information about You to any of the third parties identified above for any of the following reasons:
- To operate, manage, and maintain our business, including but not limited to, encouraging customers to purchase our products and use our services, performing services or providing goods;
- For hiring, retention, and employment purposes, including, but not limited to administering employment benefits;
- To uniquely identify an employee (e.g. using biometric information to identify an employee);
- To ensure the physical safety of natural persons;
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity or confidentiality of stored or transmitted personal information;
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the Company and to prosecute those responsible for those actions;
- Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of Your current interaction with the Company, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
- To verify or maintain the quality of safety of product, service, or device that is owned, manufactured, manufactured for, or controlled by Batory and to improve, upgrade, or enhance those services or devices.
- To otherwise accomplish our business purposes and objectives, including, for example:
- Emergency services;
- Conducting research, analytics, and data analysis;
- Maintaining our facilities and infrastructure;
- Quality and safety assurance measures;
- Conducting risk and security controls and monitoring;
- Protecting confidential and trade secret information;
- Detecting and preventing fraud;
- Performing identity verification;
- Performing accounting, audit, and other internal functions, such as internal investigations;
- Complying with the law, legal process, and internal policies;
- Maintaining records;
- Claims processing;
- Responding to legal requests for information and subpoenas; and
- Exercising and defending legal claims;
- To collect or process Sensitive Personal Information for any other reason that is not for the purpose of inferring characteristics about You; or
- Any other purposes authorized by applicable federal, state, or local law.
The Company does not disclose Your Personal Information to any third parties for purposes other than those identified above.
Right to Delete Personal Information
You have the right to request that the Company delete any Personal Information about You which the Company has collected from You, subject to certain exceptions under the CPRA, applicable laws, and regulations.
The Company does not have to delete Personal Information if it is reasonably necessary to maintain the Personal Information in order to:
- Complete a transaction for which the Personal Information was collected;
- Ensure security and integrity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech rights, ensure the right of another consumer to exercise their free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- To enable solely internal uses that are reasonably aligned with the expectations of the employee based on the employee’s relationship with the Company with the context in which the employee provided the information;
- Comply with a legal order; or
- Any other purpose permitted by applicable laws and regulations.
Right to Correct Inaccurate Personal Information
You have the right to request that the Company correct any inaccurate Personal Information that it may maintain about You, subject to certain exceptions under the CPRA, applicable laws, and regulations.
Right to Know and Access Personal Information That Is Being Collected And to Request Disclosure
You have a right to request the Company disclose to You the following information:
- The categories of Personal Information the Company has collected about You;
- The categories of sources from which the Personal Information is collected;
- The business or commercial purpose for collecting, selling, or sharing Personal Information;
- The categories of third parties to whom the Company discloses Personal Information; and
- The specific pieces of Personal Information the Company has collected about You.
All of the information that You have the right to access applies to 12 months before the Company’s receipt of Your request.
The Company is not obligated to provide the requested information more than twice to You in a 12-month period.
Right to Know What Personal Information is Disclosed, Sold, and Shared to Whom
The Company does not sell or share any of Your personal information as defined under the CPRA. As explained above, however, the Company may disclose Your Personal Information to third parties for the reasons identified above.
You have the right to request that the Company disclose the following information related to Your Personal Information that is disclosed for a business purpose:
- The categories of Personal Information that the Company collected about You;
- The categories of Personal Information that the Company sold or shared about You;
- The categories of third parties to whom the Company sold or shared about You and the categories of third parties to whom the Personal Information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared; and
- The categories of personal information that the Company disclosed about You for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
All of the information that You have the right to access applies to 12 months before the Company’s receipt of Your request.
The Company is not obligated to provide the requested information more than twice in a 12-month period.
Right of No Retaliation
The Company will not discriminate or retaliate against You because You exercised any of Your rights under the CPRA.
For Inquiries and/or to Submit Requests to Know, Delete, or Correct Information.
If You have any questions or concerns about the Company’s CPRA Privacy Policy or to submit a Request to Know, Request to Delete, or Request to Correct, please either:
- Go to https://www.batoryfoods.com/consumer-request/ and click on the “CPRA Consumer Requests” link. Once there, select the appropriate drop down menu option (e.g. Request to Know, Request to Delete, or Request to Correct).
If the Company cannot verify Your identity from the information already maintained by the Company, the Company may request additional information from You, which shall only be used for the purposes of verifying Your identity or any other permissible purposes under applicable laws and regulations.
An authorized agent may also request information on Your behalf by indicating in the “CPRA Consumer Requests” link that they are Your authorized agent.
(2) contact the Company at 800-367-6597.
When verifying consumer requests, the Company will review its human resources database, any personnel files or records, any password-protected accounts (if applicable), any other applicable online databases, or any other applicable filings and records.
The Company will update the information contained in this Policy once every 12 months.
The Company does not have any actual knowledge that it sells the Personal Information of minors.
This Privacy Policy was last updated on June 28, 2023.