Challenge Dairy Privacy Policy Challenge Dairy Products, Inc. Privacy Policy Challenge Dairy Products, Inc. (“CDPI”, or referred to collectively as “we”, “us”, “our”) collects some Personal Data from its Users (also referred to simply as “you”, “your”, “yours”) through challengedairy.com and danishcreamery.com (also referred to as “sites”). This document has a section dedicated to Californian consumers and their privacy rights. This document can be printed for reference by using the print command in the settings of any browser. Owner and Data Controller Challenge Dairy Products, Inc. (CDPI) P.O. Box 2369 Dublin, CA 94568 Phone: 1-877-883-2479 (United States Toll-Free) Email: privacy@challengedairy.com Types of Data collected Among the types of Personal Data that CDPI collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; ZIP/Postal code. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using our sites. Unless specified otherwise, all Data requested by our sites is mandatory and failure to provide this Data may make it impossible for our sites to provide its services. In cases where our site specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact us. Any use of Cookies – or of other tracking tools – by our sites or by the owners of third-party services used by our sites serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through our sites and confirm that they have the third party's consent to provide the Data to the CDPI. Mode and place of processing the Data Methods of processing CDPI takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to CDPI, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of our sites (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by CDPI. The updated list of these parties may be requested from the CDPI at any time. Legal basis of processing CDPI may process Personal Data relating to Users if one of the following applies: Users have given their consent for one or more specific purposes. Note: Under some legislations CDPI may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever provision of Data is necessary for the performance of an agreement with the User and/or for any pre- contractual obligations thereof; processing is necessary for compliance with a legal obligation to which CDPI is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in CDPI; processing is necessary for the purposes of the legitimate interests pursued by CDPI or by a third party. In any case, CDPI will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. Place The Data is processed at CDPI’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. Retention time Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore: Personal Data collected for purposes related to the performance of a contract between CDPI and the User shall be retained until such contract has been fully performed. Personal Data collected for the purposes of CDPI’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by CDPI within the relevant sections of this document or by contacting us. CDPI may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, CDPI may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period. The purposes of processing The Data concerning the User is collected to allow CDPI to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Displaying content from external platforms, and Managing contacts and sending messages. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”. Detailed information on the processing of Personal Data Personal Data is collected for the following purposes and using the following services: Analytics Contacting the User Displaying content from external platforms Managing contacts and sending messages Traffic optimization and distribution Analytics The services contained in this section enable CDPI to monitor and analyze web traffic and can be used to keep track of User behavior. Google Analytics (Google LLC) Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of our sites, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data processed: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Contacting the User Contact form (challengedairy.com) By filling in the contact form with their Data, the User authorizes CDPI to use these details to reply to requests for information, or any other kind of request as indicated by the form’s header. Personal Data processed: email address; first name; last name. Category of personal data collected according to CCPA: identifiers. Mailing list or newsletter (challengedairy.com and danishcreamery.com) By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning challengedairy.com or danishcreamery.com. Personal Data processed: email address; first name; last name; ZIP/Postal code. Category of personal data collected according to CCPA: identifiers. Displaying content from external platforms This type of service allows you to view content hosted on external platforms directly from the pages of challengedairy.com and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it. Wistia widget (Wistia, Inc.) Wistia is a video content visualization service provided by Wistia, Inc. that allows challengedairy.com to incorporate content of this kind on its pages. Personal Data processed: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Privacy Shield participant. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. YouTube video widget (Google LLC) YouTube is a video content visualization service provided by Google LLC that allows challengedairy.com to incorporate content of this kind on its pages. Personal Data processed: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Privacy Shield participant. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Google Fonts (Google LLC) Google Fonts is a typeface visualization service provided by Google LLC that allows challengedairy.com and danishcreamery.com to incorporate content of this kind on its pages. Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Managing contacts and sending messages This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message. Campaign Monitor (Campaign Monitor Pty Ltd) Campaign Monitor is an email address management and message sending service provided by Campaign Monitor Pty Ltd. Personal Data processed: email address; first name; last name. Place of processing: Australia – Privacy Policy. Category of personal data collected according to CCPA: identifiers. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Traffic optimization and distribution This type of service allows challengedairy.com and danishcreamery.com to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between our sites and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred. Cloudflare (Cloudflare Inc.) Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through our sites, i.e., communication between our sites and the User's browser, while also allowing analytical data from challengedairy.com and danishcreamery.com to be collected. Personal Data processed: Cookies and various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. The rights of Users Users may exercise certain rights regarding their Data processed by CDPI. Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with CDPI to find out which rights apply to them. In particular, Users have the right to do the following: Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. Access their Data. Users have the right to learn if Data is being processed by CDPI, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected. Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, CDPI will not process their Data for any purpose other than storing it. Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from CDPI. Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. Details about the right to object to processing Where Personal Data is processed for a public interest, in the exercise of an official authority vested in CDPI or for the purposes of the legitimate interests pursued by CDPI, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether CDPI is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. How to exercise these rights Any requests to exercise User rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by CDPI as early as possible and always within one month. Cookie Policy Cookies and other Identifiers consist of portions of code placed on the User’s device that assist CDPI in providing the Service according to the purposes described. Some of the purposes for which Identifiers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document. Activities strictly necessary for the operation of our sites and delivery of the Service Challengedairy.com and danishcreamery.com uses Cookies or other Identifiers to carry out activities that are strictly necessary for the operation or delivery of the Service and, therefore, do not require Users to consent. Users can disable such Identifiers by modifying their browser or device settings as described in more detail within this document, but this may affect core operational functions or result in the unavailability of the Service. Traffic optimization and distribution Challengedairy.com and danishcreamery.com uses Cookies or other Identifiers to distribute our content using servers located across different countries and to optimize their performance. Other activities Experience enhancement Challengedairy.com and danishcreamery.com uses Cookies or other Identifiers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms. Measurement Challengedairy.com and danishcreamery.com uses Cookies or other Identifiers to measure traffic and analyze User behavior with the goal of improving the Service. Targeting & Advertising Challengedairy.com and danishcreamery.com uses Cookies or other Identifiers to deliver personalized marketing content based on User behavior and to operate, serve and track ads. How to provide or withdraw consent Users can manage preferences regarding Identifiers directly from within their own device settings and prevent – for example – the storing of third-party Identifiers. It is also possible, via relevant browser or device features, to delete previously stored Identifiers, including those used to remember the User’s initial consent. Users can, for example, find information about how to manage Identifiers in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Edge. With regard to any Identifiers stored by third parties, Users can manage their preferences and withdraw their consent by clicking the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party. Notwithstanding the above, Users are hereby informed that they may follow the instructions provided by the Network Advertising Initiative (US), Digital Advertising Alliance (US), DAAC (Canada), or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. We thus recommend that Users make use of these resources in addition to the information provided in this document. Since the storing of third-party Cookies and other Identifiers through the services used within our sites cannot be technically controlled by CDPI, any specific references to Identifiers stored by third parties are to be considered indicative. In order to obtain complete information, the User is kindly requested to consult the privacy policies of the respective third-party services listed in this document. Given the objective complexity surrounding technologies related to Cookies and other Identifiers, Users are encouraged to contact us should they wish to receive any further information on the use of such Identifiers by challengedairy.com or danishcreamery.com. Additional information about Data collection and processing Legal action The User's Personal Data may be used for legal purposes by CDPI in Court or in the stages leading to possible legal action arising from improper use of our sites or the related Services. The User declares to be aware that CDPI may be required to reveal personal data upon request of public authorities. Additional information about User's Personal Data In addition to the information contained in this privacy policy, CDPI may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request. System logs and maintenance For operation and maintenance purposes, our sites and any third-party services may collect files that record interaction with our sites (System logs) using other Personal Data (such as the IP Address) for this purpose. Information not contained in this policy More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information at the beginning of this document. How “Do Not Track” requests are handled CDPI does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies. Changes to this privacy policy CDPI reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within our sites and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to CDPI. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, CDPI shall collect new consent from the User, where required. Information for Californian consumers This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by CDPI and, if the case may be, its parent, subsidiaries and affiliates. The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018", and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA). Categories of personal information collected, disclosed or sold In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document. Information we collect: the categories of personal information we collect We have collected the following categories of personal information about you: identifiers and internet information. We will not collect additional categories of personal information without notifying you. How we collect information: what are the sources of the personal information we collect? We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use our sites. For example, you directly provide your personal information when you submit requests via any forms on challengedairy.com or danishcreamery.com. You also provide personal information indirectly when you navigate our sites, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of our sites and features thereof. How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement. We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service. To find out more about the purposes of processing, please refer to the relevant section of this document. Sale of your personal information For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”. This means that, for example, a sale can happen whenever a website runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like. Your right to opt out of the sale of personal information You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below. Instructions to opt out of the sale of personal information If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by our sites, both online and offline, you can contact us for further information using the contact details provided in this document. What are the purposes for which we use your personal information? We may use your personal information to allow the operational functioning of our sites and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes. We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data”), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage. We will not use your personal information for different, unrelated, or incompatible purposes without notifying you. Your California privacy rights and how to exercise them The right to know and to portability You have the right to request that we disclose to you: the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared; in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose: for sales, the personal information categories purchased by each category of recipient; and for disclosures for a business purpose, the personal information categories obtained by each category of recipient. The disclosure described above will be limited to the personal information collected or used over the past 12 months. If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible. The right to request the deletion of your personal information You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on our sites, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.). If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so. How to exercise your rights To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document. For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must: provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you. If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority. You can submit a maximum number of 2 requests over a period of 12 months. How and when we are expected to handle your request We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request. We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request. Our disclosure(s) will cover the preceding 12 month period. Should we deny your request, we will explain to you the reasons behind our denial. We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it. Definitions and legal references Personal Data (or Data) Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person. Usage Data Information collected automatically through our sites (or third-party services employed in our sites), which can include: the IP addresses or domain names of the computers utilized by the Users who use our sites, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment. User The individual using our sites who, unless otherwise specified, coincides with the Data Subject. Data Subject The natural person to whom the Personal Data refers. Data Processor (or Data Supervisor) The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy. Data Controller (or Owner) The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of our sites. The Data Controller, unless otherwise specified, is the Owner of challengedairy.com and danishcreamery.com. challengedairy.com or danishcreamery.com (or Website) The means by which the Personal Data of the User is collected and processed. Service The service provided by challengedairy.com and danishcreamery.com as described in the relative terms (if available) and on this site. Cookies Small sets of data stored in the User's device. 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