NOTICE TO EU DATA SUBJECTS

 

PERSONAL INFORMATION

 

With respect to EU data subjects, “personal information,” as used in this Privacy Policy, is equivalent to “personal data” as defined in the European Union General Data Protection Regulation (GDPR).

 

HOW INFORMATION IS COLLECTED, USED AND DISCLOSED

 

We may collect certain personal information for various purposes, and we may disclose such information to various third parties.  For more information on what types of personal information is collected, from what sources, for which purposes, and how that information is disclosed, please click here: Annex 1

 

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

 

If you are a resident of the European Economic Area (EEA), Milton’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.  In addition, we process Personal Information with the principle of data minimization in mind.  This means that we limit ourselves to the minimum amount of Personal Information which is needed to achieve the particular purpose for which we process the Personal Information.  Below are some examples of the purposes for which Personal Information may be processed.

 

Milton’s may process your Personal Information because:

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• The processing is necessary to provide the services and features you have requested;

• The processing is necessary to perform a contract with you;

• The processing is necessary for the legitimate interests of our business, such as fraud prevention, information security, direct marketing, or to comply with the law;

• To fulfill a legal obligation;

• You have provided consent for us to do so.

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RETENTION OF PERSONAL INFORMATION

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We will retain your Personal Information for as long as it is necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.  For more details on data retention periods, please click here: Annex 1

 

SECURITY

 

We have adopted reasonable and appropriate security procedures to help protect against loss, misuse, and unauthorized access to the information you provide to us.  Please note, however, that no data transmission or storage can be guaranteed to be 100% secure.  As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Site and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

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COOKIE POLICY

 

An IP address is the unique number that is automatically assigned to your computer when you log onto the Internet. As you enter the website, our server records and monitors your IP address and uses it to develop statistical analysis. These analyses assist us in refining and adapting the content and design of the Site.  The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users.

 

Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology.  A cookie is a small piece of information sent by a website that is saved on your hard drive by your computer’s browser.  A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity.  They are also sometimes referred to as pixels and tags.

 

As you access or use the Site, we and/or third parties may collect information using cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy.  Such automated technologies further help us to keep track of your interactions with our website and provide you with a more customized experience.

 

We use the following cookies:

 

• Strictly necessary cookies.  These are cookies that are required for the operation of our website. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website

• Analytical/performance cookies.  They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.

• Functionality cookies.  These are used to recognize you when you return to our website so that we can personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies.  These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

At any time, you can modify your cookie settings. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

 

To find more information about cookies please visit www.allaboutcookies.org.  Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use.  By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.    

 

CROSS-BORDER DATA TRANSFERS

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Your information, including Personal Information, may be transferred to—and maintained on—computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside of the United States and choose to provide information to us, please be aware that your personal data will be transferred to, processed, and stored in the United States. Data protection laws in the U.S. may be different from those in your country of residence. We transfer your personal information out of the EEA only upon your consent. You consent to the transfer of your information, including personal information, to the U.S. as set forth in this Privacy Policy by visiting our Site. 

Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.

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Transfers to Third Parties

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Courts, tribunals, government authorities and related parties or counterparties with whom we share personal data, third-party vendors and business partners are in some cases located outside the EU. Unless the recipients are located in countries that have been deemed adequate by the European Commission, we put in place data transfer agreements based on the applicable European Commission-approved Standard Contractual Clauses to protect the personal data so transferred.  In certain cases, we may rely on statutory derogations for international data transfers.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA. Milton’s will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

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YOUR DATA PROTECTION RIGHTS UNDER THE GDPR DATA PRIVACY LAWS

 

The Data Controller

 

The Data Controller who collects and processes your Personal Information is:  Milton’s Craft Bakers, 5973 Avenida Encinas, Suite 304, Carlsbad, CA 92008.

 

Rights Under GDPR

 

If you are a resident of the European Economic Area (EEA), you have certain data protection rights.  Barring certain situations, you have the following data protection rights:

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• The right to access, update or erasure of the information we have on you.  You have the right to access, update and erase your Personal Information.

• The right of rectification.  You have the right to have your Personal Information corrected if that information is inaccurate or incomplete.

• The right to object.  You have the right to object to our processing of your Personal Information.

• The right of restriction.  You have the right to request that we restrict the processing of your Personal Information.

• The right to data portability.  You have the right to be provided with a copy of the information that we have on you in a structured, machine-readable and commonly used format.

• The right to withdraw consent.  You have the right to withdraw your consent at any time where Milton’s relied on your consent to process your Personal Information.

• The right to know about automated decisionmaking.  As a data subject you also have the right to not be subject to decisions based on automated decision making alone, including profiling, and which may lead to legal consequences for you. This right does not apply if such processing is necessary in order for Milton’s to enter into or fulfil an agreement with you, if such processing is allowed according to applicable legislation, or if the legal basis for such processing is your consent.

 

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Milton’s has implemented reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information via the online submission form at:  https://appliedsense.io/pda-request.  If you wish to be informed of the type of Personal Information we hold about you and/or if you wish to remove such Personal Information from our systems, please contact us at:  Vice President of Marketing & Innovation, Milton’s Craft Bakers, 5973 Avenida Encinas, Suite 304, Carlsbad, CA 92008 USA, Phone 858-350-9696.  Please note that for your safety and security, we may ask you to verify your identity before responding to such requests.

 

Within the EU, all user data privacy protections and concerns may be sent to Milton’s EU/UK GDPR representative:  Milton’s Craft Bakers c/o Fairway GB Ltd. 17 The Crescent, Salford M5 4PF UK, or at:  privacy@miltonsbaking.com.

 

 

CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights

 

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by Milton’s pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).  If you are not a California resident, this Notice does not apply to you.  Please visit our Privacy Policy for more information.  Any capitalized terms undefined in this Notice have the same definition as the Policy.

 

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD AND SHARED

 

Information Collected  

 

Within the past 12 months, we have collected the categories of personal information about California consumers as described in Annex 1 to this Notice.  To review these categories click here: Annex 1

 

Business-to-Business (“B2B”) Information

 

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship.  We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.  We do not disclose that information outside our business relationship without your consent.  See our B2B Privacy Notice for more details.

 

Information Sold or Shared, or Disclosed

 

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. We will share your personal information with third parties only in the ways that are described in this Privacy Policy.

As explained in Annex 1 of this Policy, we share your data with third-party partners such as social networking sites and advertising companies in order to serve you with ads tailored to your preferences across various platforms.  This type of sharing may be considered “selling” or “sharing” under the CPRA.  You can control the information shared about you and request an opt-out as explained below.  

We have disclosed the following categories of personal information for a business or commercial purpose in the preceding 12 months: 

• Personal Identifiers; 

• Commercial Information; and, 

• Internet/Network Activity

We do not sell the personal information of individuals under 16 years of age without affirmative authorization.  

For details regarding the categories of third parties with whom we have shared, sold, or disclosed personal information, please see Annex 1

 

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Requests to Know

 

You have the right to request that we disclose personal information we collect about you. 

 

To make a request for any of the information set forth above (a “Request to Know”), please submit a verifiable consumer request pursuant to the instructions below.  You may only make a Request to Know twice within a 12-month period.  We will acknowledge your Request to Know within 10 business days and will attempt to respond substantively within 45-90 days. .

 

The Request to Know must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request.  If we cannot verify your identity, we will not be able to respond to your request.

 

You can make a Request to Know the Personal Information we have about you in the following ways:

 

• You may make a request here.

• You may also make a request by phone by contacting us at 888-457-3783.

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Once we receive your Request to Know, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records.  If you are an account holder, making a request through your account is sufficient for verification purposes.  If you do not have an account with us, you will be asked to provide us with two or three pieces of information that will help us to verify your identification.  If we cannot verify your identity, we will not be able to respond to your request. 

 

RIGHT TO KNOW SENSITIVE PERSONAL INFORMATION COLLECTED

 

We do not collect or process sensitive personal information for the purpose of inferring characteristics.

 

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

 

You have the right to request the deletion of your Personal Information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.

 

The Request to Delete must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request.  If we cannot verify your identity, we will not be able to respond to your request. Additionally, as permitted by law, if the information requested to be deleted is necessary for us to maintain, we will not be able to comply with your request.  We will notify you if this is the case.

 

To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below.  We will acknowledge your Request to Delete within 10 business days and will attempt to respond substantively within 45-90 days.

Requests to Delete

You can make a Request to Delete in the following ways:

 

• You may make a request here.

• You may also make a request by phone by contacting us at 888-457-3783.

• Once we receive your initial request to delete, we will need to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. If you are an account holder, making a request through your account is sufficient for verification purposes. If you do not have an account with us, you should provide us with information that will help us to identify you.

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We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.

 

RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION

 

You have the right to opt-out of the sale or sharing of your Personal Information.  As explained in Annex 1 (add link to Annex 1) of this Policy, we share your data with third parties such as social networking sites and advertising companies, in order to serve you with ads tailored to your preferences across various platforms.  This type of sharing may be considered “selling” or “sharing” under the CPRA.  You can control the information shared about you and request an opt-out as explained below.  We will process your Request to Opt-Out of sale within 15 days.

 

Requests to Opt-Out of a Sale or Share of Personal Information

 

You can make a Request to Opt Out in the following ways:

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• You may make a request here – Do Not Sell or Share My Info.

• You may also make a request by phone by contacting us at 888-457-3783.

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Opt-out Preference Signals

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We honor opt-out preference signals that you enable, including a Global Privacy Control.  Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal information.  If you have enabled an opt-out preference signal device from your browser, we will not sell or share your personal information without first seeking your explicit consent.  

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This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices...

 

Cookies

 

Cookies are small bits of code that are stored by your computer’s web browser and that may automatically identify your browser to the Services whenever your computer is used to visit the Services. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

 

To find more information about cookies please visit www.allaboutcookies.org.

 

ADDITIONAL OPTIONS TO OPT-OUT OF SALE OR SHARING

 

In addition to the above options to opt out of the sale or sharing of your information under the CCPA as described above, you have controls and choices with respect to collection and use of your information by third parties.  These are summarized for you below.  We do not control or maintain opt-out mechanisms for third party companies and are not responsible for their operation.

 

Advertising Opt-Out

 

You can opt out of sharing your information with third-party companies engaged in targeted advertising including social networking sites such as Google, Microsoft, Instagram, Pinterest and Facebook using the following tools provided through the AdChoices website powered by the Digital Advertising Alliance (DAA):  For websites: http://optout.aboutads.info/?c=2&lang=EN.  For mobile apps:  http://www.aboutads.info/appchoices.

 

Google Opt-Out

If you would like to opt out of Google Analytics and Ads, you can.  If you are on the web, you can opt out of Google Analytics by installing Google’s Opt Out browser add on:  https://tools.google.com/dlpage/gaoptout, and you can opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated.

 

Facebook Ad Preferences

To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads.  Login to

Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.]

 

Twitter 

To understand more about Twitter’s Personalized Ads and marketing and exercise your privacy options, please visit: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads. You can learn more about Twitter’s privacy practices and policies by visiting their Privacy Policy page at https://twitter.com/privacy.

 

Pinterest 

You can opt-out from Pinterest’s interest-based ads by enabling the “Do Not Track” functionality of your web browser or by following Pinterest instructions:  https://www.pinterest.com/settings/ and updating your “Personalization” preferences.

 

Microsoft

To learn more about how Microsoft uses your data across its products and manage your privacy preferences, please visit https://account.microsoft.com/account/privacy?refd=account.microsoft.com&ru=https%3A%2F%2Faccount.microsoft.com%2Fprivacy%2F%3Frefd%3Daccount.microsoft.com&destrt=privacy-dashboard. Information on Microsoft Advertising and opt-out choices is available here: https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads

 

Instagram

To learn more about Instagram Ads and to exercise your choices please visit:  https://help.instagram.com/478880589321969/?helpref=hc_fnav&bc[0]=Instagram%20Help&bc[1]=Managing%20Your%20Account.

 

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

 

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the CCPA and CPRA, including by exercising the rights specified herein.  As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right.

 

RIGHT TO CORRECT

 

You have the right to request that we rectify inaccurate information about you. 

 

Request to Correct

 

To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below.  We will acknowledge your Request to Correct within 10 business days and will attempt to respond substantively within 45-90 days.

You can make a Request to Correct in the following ways:

 

• You may make a request here.

• You may also make a request by phone by contacting us at 888-457-3783.

• Once we receive your request to correct, we will need to verify that you are the person that is the subject of the request (through the

      Verification Process).  We will review all information provided by you to us, to determine whether the information is inaccurate.  We reserve the       right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.

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We will inform you of our decision to deny or grant your request.

 

We will retain correspondence, documents and information related to any Request to Correct for 24 months as required by law.

 

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

 

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein. 

 

RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING

 

You can request access to information about automated decision making processes Milton’s uses and you may request to opt out of automated decision making. We do not engage in automated processing. 

 

Requests to Access Information About Automated Decision Making

 

You can make a Request in the following ways:

 

• You may make a request here.

• You may also make a request by phone by contacting us at 888-457-3783.

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Once we receive your request, we will need to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You should be ready to provide us with information that will help us to identify you.

 

We will retain correspondence, documents, and information related to any request for 24 months as required by law.

 

Requests to Opt-Out of Automated Decision Making 

 

You can make a Request to Opt Out in the following ways:

 

• You may make a request here – Do Not Sell or Share My Info.

• You may also make a request by phone by contacting us at 888-457-3783.

 

NOTICE OF FINANCIAL INCENTIVE 

 

From time to time, Milton’s may provide financial incentives to consumers who elect to participate in these programs and, in connection with such programs, allow us to collect and retain certain personal information, such as Identifiers (e.g., your name, email address, or phone number), and Commercial Information (e.g., your purchase history).  These incentives may result in differences in the prices of our products offered to consumers (e.g., discounts and other promotions).  For example, the financial incentives we may provide include discounts based upon purchase activity other periodic discounts for promotional purposes. 

 

The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer.

 

Participation in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions, or contact us using the contact information below.

 

Each financial incentive or price or service difference 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, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty and repeat purchases. 

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RETENTION OF PERSONAL INFORMATION

 

We will retain your Personal Information for as long as it is necessary for the purposes set out in Annex 1 and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

AUTHORIZED AGENT INFORMATION

 

In order to allow an authorized agent to make a request on your behalf, please email us at: dthomas@miltonsbaking.com to provide your written request and consent to an authorized agent.  When your authorized agent makes a request related to your personal information, we will require the agent to provide the above written permission.  We may also require that you verify your own identity directly with us at the time such a request is made. 

 

OTHER CALIFORNIA DISCLOSURE INFORMATION

 

California Do Not Track Notice

 

Because there are not yet common, industry-accepted “do not track” standards and systems, the Site does not currently respond to Do Not Track signals.  In addition, we may allow third parties to collect Personal Information from your activity on our website, as described in the “Information Collection and Use” section above and described in Annex 1 below.

 

California Shine The Light Law Disclosure Information

 

Although we do not disclose to any third parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law.

 

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties.  To request the above information, please e-mail us at: dthomas@miltonsbaking.com or write to us at: Milton’s Craft Bakers, 5973 Avenida Encinas, Suite 304, Carlsbad, CA 92008 with a reference to California Disclosure Information.

 

We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above.  If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received.  Please note that we are required to respond to each customer only once per calendar year.

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VIRGINIA CONSUMER DATA PROTECTION ACT NOTICE

 

This Virginia Consumer Data Protection Act Notice (“Notice”) provides additional information to Virginia residents whose Personal Information is collected by Milton’s pursuant to Virginia laws, including the Virginia Consumer Data Protection Act (“VCDPA”).  If you are not a Virginia resident, this Notice does not apply to you.  Please see our Privacy PolicyPrivacy Policy (“Policy”) for more information.  Any capitalized terms undefined in this Notice have the same definition as the Policy.

 

VCDPA

 

RIGHT TO KNOW 

 

You have the right to request that we disclose to you the following information about personal information we collect from you:

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• the categories of personal data processed;

• the purpose for processing personal data;

• the categories of personal data shared with third parties; and,

• the categories of third parties with whom personal data is shared. 

 

You also have a right to know if we have sold or disclosed your personal information for a business purpose if so, the categories of personal information sold or disclosed and the categories of third parties to whom the personal information was sold or disclosed, along with the business or commercial purpose for which the personal information was sold or disclosed.

 

We have collected, used, and disclosed the categories of Personal Information about Virginia consumers as described in this Notice in Annex 1. To review these categories, click here: Annex 1

 

Requests to Know

 

To make a request for any of the information set forth above (a “Request to Know”), please submit a verifiable consumer request pursuant to the instructions below.  We will attempt to respond substantively within 45-90 days.

 

You can make a Request to Know the Personal Information we have about you in the following ways:

 

• You may make a request here

• You may also make a request by phone by contacting us at 888-457-3783.

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Once we receive your Request to Know, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records.  Upon making a request, you should be prepared to provide us with information that will help us to verify your identification.  If we cannot verify your identity, we will not be able to respond to your request.

 

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

 

You have the right to request the deletion of your Personal Information provided by or obtained about you (“Request to Delete”), subject to certain exceptions permitted by law.

 

To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below.  We will attempt to respond substantively within 45-90 days.

 

Requests to Delete

You can make a Request to Delete in the following ways:

 

• You may make a request here.

• You may also make a request by phone by contacting us at 888-457-3783.

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Once we receive your request to delete, we will need to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You should be ready to provide us with information that will help us to identify you.

 

We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months.

 

RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATION

 

You have the right to opt-out of the sale of your Personal Information.  VCDPA defines the “sale” of personal data as the exchange of personal data for monetary consideration by a controller to a third party. As explained in Annex 1 of this Policy, we and our third-party partners such as social networking sites and advertising companies, share your data in order to serve you with ads tailored to your preferences across various platforms.  This type of sharing is not considered a “sale” under the VCDPA.  If our practices change we will make sure to inform you regarding any sales of your information. 

 

Cookies

 

As explained in our “Cookies and other technology” section, you can opt out of cookies using your browser.  You may also exercise your right to opt-out of cookies using our Cookie Preference Center.

 

Please Note:

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• Opt-outs are device and browser based.  You must opt out on each device and each browser where you want your choice to apply.

• Opt-outs maybe stored via cookies.  If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.

• We may still share your Personal Information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc.  These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.

• You may still receive ads from us that are not tailored to your interests.

 

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

 

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the VCDPA, including by exercising the rights specified herein.  As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right.

 

RIGHT TO OPT OUT OF DATA PROCESSING FOR TARGETED ADVERTISING

 

You have the right to opt out of the sharing of your personal information with third parties. 

Requests to Opt Out 

 

You can make a Request to Opt Out in the following ways:

 

• You may make a request here – Do Not Sell or Share My Info.

• You may also make a request by phone by contacting us at 888-457-3783.

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RIGHT TO CORRECT

 

You have the right to request that we rectify inaccurate information about you. 

 

To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below.  We will attempt to respond substantively within 45-90 days.

 

Requests to Correct

 

You can make a Request to Correct in the following ways:

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• You may make a request here.

• You may also make a request by phone by contacting us at 888-457-3783.

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Once we receive your request to correct, we will need to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You should be ready to provide us with information that will help us to identify you.

 

We will retain correspondence, documents and information related to any Request to Correct for 24 months as required by law.

 

RIGHT TO DATA PORTABILITY

 

You can request a copy of your personal information in an easily accessible format and information explaining how that information is used. 

 

To make a request for your personal information, please submit a verifiable consumer request pursuant to the instructions below.  We will attempt to respond substantively within 45-90 days.

 

Requests for Data

 

You can make a Request in the following ways:

 

• You may make a request here.

• You may also make a request by phone by contacting us at 888-457-3783.

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Once we receive your request, we will need to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You should be ready to provide us with information that will help us to identify you.

 

We will retain correspondence, documents and information related to any request for 24 months as required by law.

 

RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED PROCESSING AND THE RIGHT TO OPT-OUT OF AUTOMATED PROCESSING, INCLUDING PROFILING

 

You can request access to information about automated processes Milton’s uses and you may request to opt out of automated processing. We [do/do not] engage in automated processing. 

 

Requests to Access Information About Automated Processing

 

You can make a Request in the following ways:

 

• You may make a request here.

• You may also make a request by phone by contacting us at 888-457-3783.

 

Once we receive your request, we will need to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You should be ready to provide us with information that will help us to identify you.

 

We will retain correspondence, documents and information related to any request for 24 months as required by law.

 

Requests to Opt Out of Automated Processing

 

You can make a Request to Opt Out in the following ways:

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• You may make a request here – Do Not Sell or Share My Info.

• You may also make a request by phone by contacting us at 888-457-3783.

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RETENTION OF PERSONAL INFORMATION

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We will retain your Personal Information for as long as it is necessary for the purposes set out in the Privacy Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

OTHER VIRGINIA DISCLOSURE INFORMATION

 

Virginia Do Not Track Notice

 

Because there are not yet common, industry-accepted “do not track” standards and systems, the Site does not currently respond to Do Not Track signals.  In addition, we may allow third parties to collect Personal Information from your activity on our website, as described in the “Information Collection and Use” section above and described in Annex 1 below