PRIVACY POLICY

Effective Date: December 20, 2024

Sartori Company and its affiliated entities (collectively, “Sartori,” “us,” “our,” or “we”) know your privacy is important. Sartori has provided this online privacy policy (this “Privacy Policy”) explaining its online information practices and the choices you can make about the way your information is collected and used. This Privacy Policy applies to the information that Sartori collects on websites owned and controlled by Sartori, including without limitation www.sartoricheese.com and http://www.sartoricompany.com/ (collectively, the “Sites”), and does not apply to information that Sartori may collect by any alternative means or media unless specifically stated otherwise.

If you are a California resident, please also see Appendix A “Privacy Information for California Residents” for supplemental California-specific privacy information.

1.     Sartori’s Collection of Your Information

Information You Provide to Us. In the course of using the Sites, Sartori may ask users for their name, email address, postal address, mobile or other telephone number, fax number, payment information, profile information, and other relevant information. Sartori may collect additional information depending on how you are using the Sites. For employment applications, Sartori may collect additional information through a third-party website (such as https://recruiting.ultipro.com), including previous work experience, education information, licenses and certifications, and other personal information. In many cases, users choose the amount of information they supply. There may be instances in which some of the information that we ask users to provide is identified as mandatory. In such cases, if users do not provide mandatory personal information with respect to a particular activity, users will not be able to engage in that activity.

Information We Collect Automatically. Sartori may collect personal information about you automatically while using or interacting with the Sites. The Sites use cookies, web beacons, or pixels (each, a “tag”). We use tags across a variety of marketing platforms which may include, but are not limited to, email delivery, analytics platforms, and advertising. If you are visiting the Sites via a mobile device, we may also collect that mobile device’s unique device ID and information about how you use the Sites from a mobile device.

The Sites may utilize certain engagement features, including session replay technology. By accessing or using any of these features, you agree that we may record and retain a transcript of all communications with you via these interactive tools, may record or recreate your activity while using the Sites, and/or may share communications with third parties in order to provide services, enhance your experience on the Sites, and for quality and verification purposes. We may work with trusted service providers to analyze, store, and/or use this data on our behalf. Your use or access of any of these tools is governed by this Privacy Policy and our Terms of Use.

We may use Google Analytics to help us understand how our customers interact with the Sites. You can read more about Google’s ability to use and share information collected by Google Analytics from Google’s privacy policy: https://policies.google.com/privacy. You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. You can also prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

Information We Collect from Third Parties. From time to time, we receive information about individuals from our third-party service providers, affiliates, agents, social media services, and partners.

2.     How Sartori Uses the Information

Except as otherwise indicated, Sartori uses personal information for the following purposes:

·       to process and fulfill your order(s) for products;

·       to create and manage user accounts;

·       to process payment;  

·       to respond to sales and/or business inquiries;

·       to respond to any of your inquiries or questions about our products and/or services;

·       for marketing purposes;

·       to engage with you on social media;

·       to improve our Sites or our products and/or services;

·       to provide you with additional and updated information, materials, and other advertisements regarding Sartori products and/or services;

·       to offer you other materials and/or information that Sartori believes may be of interest to you;

·       to cooperate with government officials or parties in litigation under process of law, to prevent a crime, or as otherwise required by law;

·       to enforce or comply with Sartori’s contracts with you or other third parties or protect the security or integrity of the Site;

·       to comply with applicable laws, including for product recalls and food safety purposes;

·       to protect against fraud, identity theft, or a threat of safety or destruction of property;

·       to protect against legal liability;

·       to evaluate you for any potential job opportunities for which you apply; and/or

·       to perform data analyses and/or research (including de-identification and aggregation of personal information).

In addition, if Sartori becomes the subject of a bankruptcy or insolvency proceeding, whether voluntary or involuntary, Sartori or its trustee in bankruptcy may disclose, sell, assign, license, or otherwise transfer such information in a transaction approved by the appropriate court.

3.     How Sartori Discloses Information

Sartori may disclose personal information with our service providers to help us operate our business. For example, our service providers help us perform statistical analysis, send you email or postal mail, or provide customer support. We may also disclose personal information with:

·         Our affiliates;

·         Our service providers, including social media networks;

·         To a buyer or other successor in the event of or during a merger, divestiture, restructuring, dissolution, or other sale or transfer of some or all of our assets or equity, whether as part of bankruptcy, liquidation, or similar proceeding, in which personal information is among the assets transferred; or

·         With your consent.

Sartori may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with laws and legal process served on Sartori; (b) protect and defend the rights or property of Satori; and/or (c) act under exigent circumstances to protect the personal safety of users of the Sites or the public.

4.     Children

The Sites are not intended for children under the age of 16. Sartori does not knowingly collect or sell personal information from users under 16 years of age. In the event that Sartori becomes aware that it has collected personal information from a user under 16 years of age, it will take steps to delete such information from its database. If you believe that we might have any information from or about a child under the age of 16, please contact us at customercare@sartoricheese.com.

5.     Opt Out

You may choose not to receive marketing materials regarding Sartori products by simply notifying Sartori directly at customercare@sartoricheese.com. Upon receipt and processing of an “opt-out” request, Sartori will, within a commercially reasonable amount of time, remove your information from any future unsolicited marketing communications. Your request not to receive marketing materials will not apply to information that you request to receive.

If you do not wish us to place cookies, you may set your browser to refuse some cookies, or to alert you when cookies are being sent. You may also adjust your cookie settings by clicking the link at the bottom of our page titled “Cookie Settings.” [AF1] Please note, if you choose to opt out of cookie usage, cookies essential to the operation of the website will still be in use and placed. If you do so, please note that some parts of the Sites may then be inaccessible or may not function properly. Information on deleting or controlling cookies can be found at www.aboutcookies.org.

If you are a California resident, please also see Appendix A titled “Privacy Information for California Residents” for further information about additional rights you may exercise.

6.     Security, No Liability

Sartori uses reasonable efforts to implement security measures designed to help protect against the risk of loss, misuse, and alteration of any information under Sartori’s control. Nevertheless, please keep in mind that such security measures may not prevent all loss, misuse, or alteration of information on the Sites, and transmission of information over the internet and on mobile platforms is not always secure, which means we cannot and do not guarantee the security or confidentiality of any information that you provide to us. Given this reality, your use of our Sites and your decision to provide personal information to us is at your own risk. Sartori is not responsible for any damages or liabilities relating to any such security failures.

Furthermore, email is not a secure form of communication. Please do not send us your Social Security number, credit card number, or other sensitive personal information via email. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your data transmitted to and from our Sites or over mobile networks; any transmission is at your own risk. You understand that data and communications, including email and other electronic communications, may be accessed by unauthorized third parties when communicated over the internet.

7.     Third-Party Websites

The Sites contain links to other websites that do not belong to Sartori. Sartori is not responsible for nor can Sartori ensure the privacy practices or content of such other websites, and this Privacy Policy does not apply to those other websites. You should always read the privacy policy of a website before disclosing any of your information.

For employment applications, you will be redirected to a website called https://recruiting.ultipro.com, which is controlled by Ultimate Software. The website will collect personal and employment related information about you. Please make sure to read Ultimate Software’s privacy policy, which is located at https://www.ultimatesoftware.com/Privacy-Policy.

8.     Modification of Privacy Policy

Sartori may change this Privacy Policy at any time by posting the changed or amended Privacy Policy on the Sites. Your continued viewing of or use of the Sites following the posting of any changes to this Privacy Policy will signify your assent to any such changes or amendments.

9.     How to Contact Sartori for Any Reason

You may contact Sartori with questions or comments regarding this Privacy Policy or to update any personal information at customercare@sartoricheese.com.

Appendix A

Privacy Information for California Residents

This Appendix applies solely to individuals who reside in the State of California (“consumers” or “you”). This Appendix complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Appendix. This Appendix applies to personal information of California residents collected both online through the Sites and offline when you otherwise interact with or conduct business with Sartori. This Appendix does not apply to personal information outside the scope of the CCPA. For information on how Sartori uses your personal information, please see Section 2 “How Sartori Uses the Information” above.

1.     Disclosures

The below chart lists the categories of personal information that Sartori may collect or has collected in the past 12 months and how Sartori discloses such information.

Categories of Personal InformationCategories of Third Parties with Whom Personal Information is Disclosed
Identifiers. This may include a real name, alias, address, email address, phone number, online identifier, IP address, account username and password, or other similar identifiers. Entities that we are legally required to share with pursuant to law or for legal proceedings; service providers; prospective purchasers of our business; our affiliates; outside auditors and lawyers; and social networks.
Internet and network information. This may include information on your interaction with a website, application, or advertisement, such as browsing history and how you use your account.Entities that we are legally required to share with pursuant to law or for legal proceedings; service providers; our affiliates; outside auditors and lawyers; and social networks.
Device information. This may include the operating system of your device, device identifier, the type of device you are using, or your geolocation information.Entities that we are legally required to share with pursuant to law or for legal proceedings; our affiliates; service providers; and social networks.
Order information. This may include information about what you order, shipping, returns, product complaints, or warranties.Entities that we are legally required to share with pursuant to law or for legal proceedings; our affiliates; service providers; and social networks.
Payment and credit information. This may include your credit or debit card information, banking information, information about your payment transaction, or other financial information you provide us. Entities that we are legally required to share with pursuant to law or for legal proceedings; our affiliates; service providers; and social networks.
Other information you submit to Sartori or its service providers. This may include requests or communications you submit to us, emails, ratings, social media communications, or customer service call recording.Entities that we are legally required to share with pursuant to law or for legal proceedings; our affiliates; service providers; and social networks.
Research or survey information. This may include survey results and other information about your participation in our research trials, such as information regarding your activities and preferences. Entities that we are legally required to share with pursuant to law or for legal proceedings; our affiliates; service providers; and social networks.
Inferences about you. This may include information about your preferences, characteristics, predispositions, behavior, or other trends that help us identify which products you may be interested in.Entities that we are legally required to share with pursuant to law or for legal proceedings; our affiliates; service providers; and social networks.
Applicant or employment information. This may include your name, address, resume, work history, education, cover letter, drug screening information, and background check information.Entities that we are legally required to share with pursuant to law or for legal proceedings; our affiliates; service providers; and social networks.

2.     Sources of Information

Sartori collects personal information from the following sources: you, your agents, our third-party service providers, and social media networks.

3.     “Sale” and “Sharing” of Personal Information

In the past 12 months, we have not sold or shared personal information.

4.     Retention

Sartori retains the information listed above in accordance with its data retention practices or as otherwise may be required by law.

5.     California Residents’ Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information, described below. Below are your CCPA rights and how to exercise those rights.

a.     Access to Specific Information and Data Portability Rights

You have the right to request that Sartori disclose certain information to you about its collection and use of your personal information over the past 12 months. You may request:

·       The categories of personal information Sartori collected about you;

·       The categories of sources of personal information Sartori collected about you;

·       Sartori’s business or commercial purpose for collecting that personal information;

·       The categories of third parties with whom Sartori discloses that personal information; or

·       The specific pieces of personal information Sartori collected about you.

b.     Deletion Request Rights

You have the right to request that Sartori delete some or all of the personal information that it has collected from you and retained, subject to a number of exceptions. Sartori is not required to delete personal information[MB2] [AF3] that is: (i) necessary to complete a transaction with you or for warranty or product recalls; (ii) used for security purposes, to prevent fraud, to fix errors, or to comply with law; (iii) reasonable for Sartori to use for internal purposes given its relationship with you; or (iv) compatible with the context in which you provided the information. The list of exceptions above is not exhaustive, and we may also deny a deletion request as otherwise permitted by law.

c.     Correction Rights

You have the right to request that Sartori corrects inaccurate personal information that Sartori maintains on you.

d.     Exercising Your Rights

To exercise your rights described above, please submit a verifiable consumer request to Sartori by either:

·       Calling us at 1-800-558-5888.

·       Emailing us at customercare@sartoricheese.com.

Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

·       Provide sufficient information that allows Sartori to reasonably verify you are either the person about whom we collected personal information or an authorized representative therefor; and

 

·       Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Sartori may not be able to fulfill your request or provide you with personal information if it cannot verify your identity or authority to make the request and confirm the personal information relates to you. To verify your identity, Sartori may request up to three pieces of personal information about you, and Sartori reserves the right to take additional steps as necessary to verify your identity if it has reason to believe a request is fraudulent.

e.     Response Timing and Format

Sartori endeavors to respond to a verifiable consumer request within 45 days of its receipt. If Sartori requires more time (up to 90 days), it will inform you of the reason and extension period in writing. Sartori will deliver the written response by mail or electronically, at your option.

The response Sartori provides will also explain the reasons it cannot comply with a request, if applicable. For data portability requests, Sartori will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

f.      Non-Discrimination

You have the right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, Sartori will not:

·       Deny you goods or services;

·       Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;

·       Provide you a different level or quality of goods or services; or

·       Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

6.     Notice of Financial Incentives

We offer certain voluntary incentive programs that provide certain perks, such as product discounts. We may also provide other voluntary programs, such as contests or other similar promotional campaigns (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your contact information (such as an email address). You may opt out of these Programs at any time by contacting us through the contact methods described above under the section titled “Exercising Your Rights” or through any additional methods described to you through the Programs. Because our Programs involve the collection of personal information and offering of certain benefits, they might be interpreted as a “financial incentive” program under California law. Under the California law, the value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants.