FSD PRIVACY PRINCIPLES
FSD takes your privacy seriously. The following principles guide our treatment of your personal information:
- We value the trust you place in FSD when sharing your personal information with us.
- We strive to be transparent with you about what personal information we collect, what we do with it and with whom we share it.
- We endeavor to work with you to address your concerns about how we use your personal information.
- We strive to take steps designed to secure your personal information and reduce the risk it will be misused.
FSD PRIVACY POLICY
Last Updated Date: (INSERT DATE)
SCOPE
This Privacy Policy ("Policy") describes how FoodServiceDirect ("FSD," "we," "us," or "our") collects, uses, shares and otherwise processes personal information in connection with our websites where the Policy is located, including the mobile versions of our websites (the "Platform"). This Policy is not, however, a contract and does not create any legal rights or obligations.
When we use the term "personal information" in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you or a particular household, publicly available information from government records, employees and other personnel or information about the employees.
Types of Sensitive Personal Information
We will only process your Sensitive Personal Information in accordance with applicable law. We only process your Sensitive Personal Information for purposes listed in Section 7027(m) of the California Consumer Protection Act regulations.
| Category of Personal Information | Use Cases | Categories of Recipients to Whom Personal Information is Disclosed for Business Purposes | Categories of Third Parties to Whom Personal Information Is Sold or Shared for Targeted or Behavioral Advertising |
|---|---|---|---|
| Account Credentials Allowing Access to An Account | To provide our products and services; to respond to your requests; to communicate with you; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you. | Service Providers or Contractors; Data Management Platforms; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies | N/A |
| Precise Geolocation from Your Device | To provide our products and services; to respond to your requests; to communicate with you; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you. | Service Providers or Contractors; Data Management Platforms; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies | N/A |
In addition to the uses above, we may use or disclose your personal information if we take part in or are involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of our company assets, during negotiation of, in connection with or as an asset in such a corporate business transaction, or in the event of insolvency, bankruptcy, or receivership.
Sources of Information
We collect the types of personal information listed in the tables above in the following ways:
Directly From You. When you interact with us on our Platform (including one of our websites, sending us an email, visiting us at an in-person promotional event, or calling our Customer Service Department) or interacting with FSD social media pages, we may collect the personal information you share with us.
Automatically When You Interact with Our Platform, Our Emails or Advertisements. Subject to your device settings, FSD will automatically collect certain personal information when you interact with our Platform on any device, when you click on sponsored links or third-party ads to visit our Platform, and we may also collect personal information about you over time and across different websites, apps and devices when you use our Platform, using tracking technologies such as cookies, pixels, Flash objects, APIs and mobile software development kits (SDKs) and we may use third party services to collect this personal information when you use our Platform. We explain more about our use of cookies and other tracking technologies in the section called "Tracking Technologies, Interest-Based Advertising and Third-Party Tracking" below.
From Our Affiliates. We may collect personal information about you from our affiliates.
From Third Parties. We may receive personal information about you from third-party sources, such as our business partners, including online advertising networks, analytics vendors, and companies that co-sponsor our promotions, social media sites, third-party sites, family, friends or others who provide your personal information to us because they think you might be interested in our products or services or they want to share a product or service with you, or companies that provide personal information to supplement what we already know about you, including data aggregators. Certain third parties might link your name or email address to other information they have collected. That might include past purchases made offline or online. It might also include online usage information collected by third parties and shared with us.
By Combining Personal Information. For example, we may combine personal information that we collect offline with personal information we collect through our Platform, combine personal information we collect about you from the different devices you use to access our Platform, or combine personal information we get from third parties with personal information we already have about you.
ONLINE ADVERTISING AND THIRD PARTY TRACKING
Cookies & Other Tracking Technologies: We automatically collect certain types of usage and device information when you visit our Platform, read our emails or otherwise engage with us. We typically collect this information through use cookies (a small text file sent from a website and stored on your device), web beacons or pixels and similar tracking technologies, and we may utilize third party services to collect this information. For example, these tracking technologies may collect information about your device and its software, such as your IP address, browser type, device type, date and time stamp, unique device ID, and about the way you engage with our Platform, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, how frequently you access our Platform, whether you open emails or click the links contained in emails, whether you access our Platform from multiple devices, the products you view and click on, and similar actions you take. You can learn more about how to control cookies in our "Your Privacy Choices" section below.
We use this information collected through tracking technologies to allow you to browse our Platform and use its features, to provide custom, personalized content and information, including targeted content and advertising, to measure the effectiveness of our advertising, to recognize you across multiple devices, to remember your preferences, to monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, to identify errors and resolve them, to analyze Platform performance, to improve our Platform, and otherwise enhance our Platform and your user experience.
Interest-Based Advertising: We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests. This means that we permit third party online advertising networks, social media companies, and other third-party services to collect information about your use of our websites and Platform over time so that they may play or display ads on our Platform, on other websites, apps, or services you may use, and on other devices you may use. Advertisers use advertising identifiers such as cookies, hashed email or phone number, or mobile advertising identifiers, to support their delivery of interest-based advertising. To learn more about these advertising IDs, you can visit https://www.aboutidentifiers.org/. To learn more about your choices regarding interest-based advertising, visit the "Your Privacy Choices" section below.
We learn from groups of consumers sharing similar interests. We may place you in a group of consumers who show the same interests (sometimes these are called "look alike audiences"). We may infer these things about you based on your activity on certain webpages, links you click on our Platform and other websites you visit, mobile applications you use, or our brand emails you view and links you click in the emails, and based on other information we have collected, such as from retail partners and other third parties. We group together information to help us learn about general trends, habits or characteristics about a group of consumers who act similarly online or offline and use this information to send this group information we believe will be relevant product offers or information.
We link information to an advertising identifier, which may be device specific (such as a cookie, mobile ad ID, or hashed email address or hashed phone number). This information may be supplemented with information such as products you buy offline or information you provide directly to us on our Platform. We generally do this in ways that will not directly personally identify you (they are "masked" by a number identifier instead of associated with information like your name), but if we personally identify you we will do so in accordance with applicable laws.
We may know you across your devices, such as computers, phones, tablets because we associate device-specific identifiers. We assume that the same person or household owns certain devices based on certain activities, such as connecting the devices to the same WiFi network.
We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices or serve you ads on social media sites you may use. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
Google Analytics and Advertising: We use Google Analytics to better understand how our users interact with our Platform. Our ability to use and share information collected by Google Analytics about your visits to our sites is restricted by the Google Analytics Terms of Use (https://marketingplatform.google.com/about/analytics/terms/us/) and the Google Privacy Policy (https://policies.google.com/privacy). To understand how Google uses data when you use our partners' sites or apps, visit https://policies.google.com/technologies/partner-sites. You may opt out of Google Analytics at any time by visiting https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by visiting NAI's online resources at https://optout.networkadvertising.org/?c=1.
Pixels: Pixels are small objects embedded into a web page but are not visible. They are also known as "tags," "web bugs," or "pixel gifs." We use pixels to deliver cookies to your computer, monitor our website activity, make logging into our sites easier, and for online marketing activities including personalized advertising on social media sites. We also include pixels in our email messages or newsletters to determine whether you open them and click on their links. This helps us understand whether you are an active user. It also helps us measure the effectiveness of our marketing efforts, and derive insights and analysis, that we will use to personalize the content of our communication and to guide our marketing decisions and strategy.
Our Do Not Track Policy: Some browsers have "do not track" features that allow you to tell a website not to track you. These features are not all uniform. Where available, you may choose to enable an online tool that automatically communicates your universal opt-out preferences, such as the Global Privacy Control ("GPC"). You may need to use a specific browser or an extension that supports these tools and universal signals. When detected, we will process such a signal as a request to opt out of tracking PI and as a request to opt out of "sale" or "sharing" of your data as explained in the "Your Privacy Choices" section below. You can also opt-out of such tracking directly on our Platform by following the steps noted in the Interest-Based Advertising section above. If you have questions, please contact us via one of the methods listed in the "How to Contact Us" section at the end of this Notice.
YOUR PRIVACY CHOICES
Marketing Communications: You can opt out of receiving our marketing communications. Note that you will still receive non-marketing or transactional messages from us, including messages about your account, orders, and responses to your inquiries. To opt out of receiving our marketing communications, you can contact us as follows:
- Send us an email at privacy@foodservicedirect.com.
- If you have an account with us, then by logging into your account and modifying your newsletter, marketing and promotional subscriptions and preferences.
- For promotional emails or text messages, follow the instructions included with the marketing communication.
Mobile Application and Location Based Services:
- You may control our collection and use of location-based information through our mobile applications by adjusting the settings on your mobile device. If you withdraw permission for mobile applications to access precise location data, we may continue to approximate your location based on information like your IP address.
- You may completely opt out of all location-based information collection by us if you uninstall all of our mobile apps from your devices.
How to Exercise Choice for Interest-Based Advertising – Advertising Industry Opt-Outs: To exercise choice with respect to interest-based advertising, you can use the opt-out mechanisms provided by the Digital Advertising Alliance (DAA) by visiting https://youradchoices.com/token (for device identifier-specific opt outs), https://optout.aboutads.info/?c=2&lang=EN (for desktop or mobile browser advertising) or https://youradchoices.com/appchoices (for in-app advertising). You can also use the Network Advertising Initiative's (NAI) tool: http://www.networkadvertising.org/choices/. To opt-out of Unified ID 2.0 globally visit: https://www.transparentadvertising.com/.
Even if you opt-out of certain kinds of interest-based ads, you may continue to receive other ads. And opting out of one or more DAA or NAI members only means that those selected members should no longer under the DAA / NAI rules deliver certain targeted ads to you. This will affect services provided by the applicable DAA / NAI members but does not mean you will no longer receive any targeted content and/or ads from non-participating parties. Also, if your browsers are configured to reject cookies when you visit the opt-out page, or you subsequently erase your cookies, use a different Device or web browser(s), or use a non-browser-based method of access, your DAA / NAI browser-based opt-out may not, or may no longer, be effective. Mobile device opt-outs will not affect browser-based Interest-based ads even on the same device, and you must opt-out separately for each device. We are not responsible for the effectiveness of, or compliance with, any third party opt-out options or programs or the accuracy of their statements regarding their programs.
You can also prevent or reduce getting interest-based ads on websites by declining cookies in your browser(s), or on mobile devices by declining the "access to data" requests that apps usually present when you install them or by adjusting the ad tracking settings on your device.
You will still see "contextual" ads even if you opt out of interest-based ads. Even if we stop sending you interest-based ads, you will still get ads from our brands on your computer or mobile devices. These ads, however, are based on the context of the sites you visit and are called contextual ads. Unlike interest-based ads which are based on pages you visit on your mobile phone or computer viewing activities over time and across unrelated services, contextual ads are ads shown to you based on the context of the specific site you are visiting. You should also know that we may still collect information from your computer or devices and use it for other purposes like evaluating how our websites work, for consumer research, or detecting fraud, pursuant to applicable laws.
How You Can Control Cookies:
- Your browser may give you the ability to control cookies or other tracking technologies, or to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can visit https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. Why? Because flash cookies cannot be controlled through your browser settings.
- If you block cookies, certain features on our Platform may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques. In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use.
- When you opt out of interest-based advertising, an opt-out cookie is sent to your browser that indicates you no longer want to receive interest-based ads. Your opt-out cookie will be deleted if you decide to delete all cookies on your browser. You will need to opt out again on each browser when you clear or delete cookies if you do not want to receive interest-based advertising.
Privacy Rights
We offer certain privacy rights as stated below, subject to certain limitations at law.
Right to Know – The right to request the following information relating to the personal information we have collected about you and disclosed about you: The categories of personal information we have collected about you; The categories of sources from which the personal information was collected; The business or commercial purposes for collecting, selling, or sharing the personal information; The categories of third parties with whom the business shares personal information; The categories of personal information sold, and for each category identified, the categories of third parties to whom it sold that particular category of personal information; and The categories of personal information that the business disclosed for a business purpose, and for each category identified, the categories of third parties to whom it disclosed that particular category of personal information.
Right to Access (Right to Know Specific Pieces of Information) / Portability – The right to access and obtain a copy of the specific pieces of personal information we have collected about you in a structured, machine-readable format that may be transmitted to another entity without hindrance, to the extent technically feasible.
Right to Correct – The right to request that we correct your inaccurate personal information maintained by us.
Right to Request Deletion – The right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions.
Right to Opt Out of Data Sales or Sharing (Targeted Advertising or Profiling) – The right to direct us not to sell or share personal information we have collected about you to third parties, including for ad targeting/cross-contextual behavioral advertising. DO NOT SELL OR SHARE MY PERSONAL INFORMATION
California's "Shine the Light" Law – California's "Shine the Light" law (Civil Code § 1798.83) also permits California residents that have an established business relationship with us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year or to have the right to opt-out of such disclosures. To opt out of this type of sharing, please follow the "Right to Opt Out of Data Sale or Sharing (Targeted Advertising or Profiling)" instructions below.
HOW TO EXERCISE YOUR PRIVACY CHOICES
To Exercise Your Rights to Know, Access, Correct, or Delete: You can submit a request via email at privacy@foodservicedirect.com. We may need to verify your identity before processing most requests, which may require us to obtain additional personal information from you. In order to verify your identity, we will generally require either the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. Please provide your name, email address and mailing address in the original request, as well as an explanation of the rights you wish to exercise. We will only use the personal information provided in connection with a Privacy Rights Request to review and comply with the request. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.
If you wish to submit a verifiable consumer request on behalf of another individual we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf. Please see the "Authorized Agents" section below for more information. In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.
To Exercise Your Right to Opt Out of Personal Information Sales or Sharing (Targeted Advertising or Profiling): As is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third-party businesses to collect personal information directly from your browser or device through cookies or similar online tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, geolocation data, commercial information, and inferences or consumer profiles generated from your browsing history and interactions with our service as well as other sites and services. These third parties use this information for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell or share that information to other businesses for advertising and other purposes.
We have two separate sets of instructions for exercising your Right to Opt Out: for Tracking Technology personal information (such as cookie ID, IP address, online IDs or electronic activity information) ("tracking PI") and for information that we have previously collected directly from you or otherwise about you (such as your email address) ("non-tracking PI"). In either case, you do not need to create an account with us to exercise your Right to Opt Out.
How to Opt Out of non-tracking PI: To exercise your Right to Opt Out of non-tracking PI, please submit a request by emailing privacy@foodservicedirect.com. We may ask you to provide additional personal information (including your name, email address and mailing address) so that we can properly identify you in our dataset to facilitate the opt-out request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by emailing privacy@foodservicedirect.com.
How to Opt Out of tracking PI: To exercise your Right to Opt Out of tracking PI, visit DO NOT SELL OR SHARE MY PERSONAL INFORMATION. You will be taken to our cookie management tool with instructions for using the toggle to enable certain cookie preferences on your device. Some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, the options you select relating to interest-based advertising are browser and device specific. If you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again. Where available, you may choose to enable an online tool that automatically communicates your universal opt-out preferences, such as the Global Privacy Control ("GPC"). You may need to use a specific browser or an extension that supports these tools and universal signals. When detected, we will process such a signal as Right to Opt Out of tracking PI request.
Personal Information of Minors Under Age 18: We do not "sell" or "share" for targeted or cross-context behavioral advertising personal information of consumers we know to be less than 18 years of age. Our Platform is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under 18.
Authorized Agents: In certain circumstances, you are permitted to use an authorized agent to submit privacy rights requests on your behalf. We may verify the authorized agent's authority to act on your behalf as follows: For requests to opt-out of personal information "sales" or "sharing," we may ask you to provide a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf. For all other requests, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Policy, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
Nondiscrimination: We do not discriminate against you for requesting any of the rights noted above. We are permitted to deny or limit your request in accordance with applicable laws.
Right to Know Specific Third Parties: In certain circumstances, you may have a right to request information about specific third parties with whom we share personal information. You may make this request by emailing privacy@foodservicedirect.com.
Right to Appeal: In certain circumstances, we may decline a request to exercise the rights described above. If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by emailing at privacy@foodservicedirect.com.
Privacy Rights Metrics: Click here to see request metrics.
SMS/MMS Marketing and Communication
Collection of Mobile Phone Numbers: We collect mobile phone numbers when you opt-in to our SMS/MMS marketing services. This may occur when you provide your mobile phone number on our website, during account registration, or as part of purchasing processes.
Use of Personal Information for SMS/MMS Marketing: When you opt into our SMS/MMS marketing services, we use your mobile number to send you promotional messages about our products, services, and special offers. The frequency of these messages will vary but will be clearly communicated during the opt-in process.
Opt-In Consent: By providing your mobile number and opting into our SMS/MMS marketing services, you give us explicit consent to send you text messages. We will provide a clear and concise method for you to give this consent.
Opt-Out and Withdrawal of Consent: You can opt out of our SMS/MMS marketing services at any time. Instructions for opting out will be included in every marketing SMS/MMS we send. Upon opting out, you will no longer receive marketing texts from us, but you may still receive transactional messages (e.g., order confirmations).
Third-Party Service Providers: We may use third-party service providers to facilitate our SMS/MMS marketing. We ensure these providers adhere to strict data protection and privacy standards.
Changes to SMS/MMS Marketing Practices: If we make changes to our SMS/MMS marketing practices, we will update this policy accordingly. You will be notified of any significant changes as per our standard policy update procedures.
FINANCIAL INCENTIVES
From time to time, we may offer you certain financial incentives permitted by law (such as coupons, samples, and loyalty programs) in exchange for the collection, retention, or use of certain personal information about you. Each financial incentive related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business. When necessary, we will provide information about the specific terms of the financial incentive, such as the type of personal information required to be disclosed, retained or sold in exchange for the benefit you may receive, and instructions on how to opt in or opt out, on the webpage or form where the financial incentive is made available.
SECURITY
The Internet is not 100% secure. Like all businesses, we cannot guarantee the security of the personal information you provide to us via the Platform. We have, however, taken certain steps designed to reduce the risk that the personal information you provide us will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction. We encourage you to use caution when using the Internet. A user ID and a password are needed to access certain areas of the FSD Platform. It is your responsibility to protect your username and password.
STORAGE OF INFORMATION
Our Platform is directed only to U.S. consumers for products and services of Unilever United States and only intended for use in the U.S. Our Platform is not directed to consumers outside of the U.S. Personal information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.
RETENTION OF PERSONAL INFORMATION
The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected. The duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations or rights.
LINKS TO THIRD-PARTY SERVICES
Our Platform may contain links to other third-party sites, plug-ins, applications or other online services. If you click on a link to a third-party site or other online service, you will be taken to a site or other online service we do not control and that is not governed by this Policy. We are not responsible for the privacy practices used by third-party sites and other online services. We suggest that you read the privacy policies of those sites and other online services carefully.
HOW TO CONTACT US
If you have any questions, comments, or concerns regarding our privacy practices or this Policy, or if you wish to update your information, please feel free to contact us:
- Email: privacy@foodservicedirect.com
- Telephone: 855-705-0755 (Monday through Friday, 9:00 AM – 5:00 PM Eastern)
CHANGES IN POLICY
From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy of this Policy on our Platform. Please check our Platform periodically for updates.