1. INFORMATION WE COLLECT ON OUR PLATFORMS.
We collect, receive, and develop several categories of personal information about you, depending on the nature of your interactions with us. For example:
We Collect Contact Information. We collect contact information and identifiers such as your name, email, telephone number, social media account handles, and home address. If our Platform allows you to create an account, we collect a username and password from you. We also collect business contact information on our Platforms for our business customers, including a job title, company name, and business email or telephone number.
We Collect Demographic Information. We may collect information such as your gender, birth date, and age.
We Collect Location Information. We collect information about your general location, using your zip code and IP address.
We Collect Audio, Visual, or Similar Information. We collect photos and videos you submit in connection with a promotion, or that you send to us through our Platforms. If you participate in a video call with us as part of a promotion prize, we may record that call. For certain Platform features, if you give permission, our Platform can access the camera and microphone on your device.
We Collect Internet and Network Activity Information.
Usage Information. Whenever you visit or interact with the Platforms, we, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Platforms are accessed and used (“Usage Information”). Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features or applications on the Platforms, interactions with friends, and group activities.
Device Identifier. We automatically collect your IP address and other unique identifiers (“Device Identifier”) for the device (computer, mobile phone, tablet or other device) you use to access the Platforms. A Device Identifier includes a number that is assigned to your device when you access a website or its servers, and we may identify your device by its Device Identifier.
Cookies; Pixel Tags. The technologies used on the Platforms to collect Usage Information, including Device Identifiers, may include but are not limited to: cookies (data files placed on a device when it is used to visit the Platforms), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed). We collect information about users over time and across different websites through these technologies and tools when you use our Platforms. For example, we may look at what site you came from, or what site you visit when you leave us. We may look at search terms or other data you enter, mouse movements, keystrokes, clicks, links you access, or screen captures. Third parties help us collect personal information this way. For more information about these technologies, see the “Advertising/Behavioral Targeting; How to Opt Out” section below.
We Collect Payment Information. If you make a purchase from us directly on our Platform, we collect your credit card, billing address, and other payment details.
We Collect Purchase and Preference Information. If you make a purchase from us directly on our Platform, we collect information about your purchase history, shipping instructions, and product preferences. We also collect information about other offline transactions and shopping preferences.
We Collect Employment-Related Information. When you apply for a job, we collect information you submit as part of your application and resume. This might include your work experience and previous employment, your education, your eligibility to work in the United States, languages you speak, and your salary expectations. It might also include information about non-compete or non-solicitation agreements you may have signed, or your relationship to any of our current employees. Certain job applications may ask additional questions specific to the position. If you apply for a job, you may choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status.
We Collect and Develop Inferences. Using the other pieces of personal information collected about you, we may draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes.
We Collect Other Information You Submit or Send. We collect other information you provide when you contact us, use our “chat” features, make a request, complete a survey, or participate in a promotion. For example, if you win a prize in one of our promotions, we will collect a Social Security Number or other tax ID number. On our Platforms directed to business contacts, we collect information you provide to us about your company, where it operates, and its products, websites, sales, sales channels, and funding. We may collect other information you provide to us about your business, including why you want to work with us and documents related to your company and products.
Sensitive Information. Some of the information described above may be considered “sensitive” under the laws of certain jurisdictions (including payment information, account login credentials, government ID numbers, and employment-related demographic information) (“Sensitive Information”). Whether information is Sensitive Information will depend on the laws of your jurisdiction.
2. HOW WE USE THE INFORMATION WE COLLECT
We use the categories of personal information referenced above for the following purposes:
We use information to provide you with services, and respond to your questions and requests. We use Contact Information, Internet and Network Activity Information, Location Information, Payment Information, Purchase and Preference Information, and Inferences to provide you with certain services and provide access to certain areas and features of the Platforms (such as your favorite products). We also use these categories of information to verify your identity, and to communicate with you, including about your activities on the Platforms and, in our discretion, changes to any of our policies. We use Contact Information, Purchase and Preference Information, Location Information, and Payment Information to process purchase transactions. We may also use Location Information for the purpose of providing you with certain features on the Platforms, including to find products at stores near you. Cookies may also use personal information to associate you with social networking sites like Facebook and Twitter and, if you so choose, enable interaction between your activities on the Platforms and your activities on such social networking sites.
We use information for marketing purposes, including for targeted advertising. For example, we may use personal information like Contact Information, Demographic Information, Location Information, Internet and Network Activity Information, Purchase and Preference Information, and Inferences to tailor content, advertisements, and offers we serve you. This information helps us keep our Platforms fresh and interesting to our visitors and allows us to tailor ad content to your interests (such as allowing us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information). To learn about your choices for these communications, read the “Your Privacy Rights, Choice and Access” and the “Advertising/Behavioral Targeting; How to Opt Out” sections below.
We use information to evaluate and improve our products and services. We use all categories of personal information to make our Platforms, products, and services better. For example, we use Internet and Network Activity Information to analyze trends, track users’ web page movements, help identify you, and gather broad demographic information for aggregate use. We, or our vendors, may place cookies or similar files on your device for analytics, Platform performance, and security purposes, and to facilitate site navigation.
We use information to comply with our obligations, administer our Platforms, and for internal operations. We may use all categories of personal information to keep the Platforms functional, to provide content on the Platform, to troubleshoot problems with the Platforms’ operations, and help diagnose problems with our servers. For example, a pixel tag may tell your browser to get content from another server. We may also use personal information to comply with our content license obligations.
We use information to conduct due diligence and transact with your company. If you are a business contact, we use information you provide to conduct due diligence regarding a product or service your company may offer. We may also use information in the context of providing or receiving a product or service to or from you and your company.
We use information for security purposes. For example, we may use all categories of personal information to protect our company, our customers, and our business partners. We also may use personal information to protect our Platforms or our services, as well as to detect and investigate activities that may be illegal or prohibited (such as cyberattacks or fraudulent transactions).
We use information for hiring purposes. For example we use Contact Information and Employment-Related Information to review your job applications and contact you about employment opportunities. We may use certain Employment-Related Information for other statistical or analytical purposes in accordance with applicable law.
We use information to verify requests made pursuant to this Privacy Notice. We will use certain pieces of personal information, such as Contact Information, to verify your identity if you make requests pursuant to this Privacy Notice. The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and nature of your request.
We use Sensitive Information for necessary or reasonably expected purposes – specifically, to provide you with services on our Platforms (i.e., to fulfill purchases and allow account logins), to evaluate your application for employment, for tax purposes, and as authorized by law.
We may use information as otherwise disclosed or permitted by law, or as we may notify you. For example, we will use your personal information for purposes we describe when you enter a contest or sweepstakes. We also use information for due diligence; as otherwise permitted or required by law, regulation, or court order; or if a government agency or investigatory body requests it. We may use de-identified or aggregated data for any purpose, unless prohibited by law. We do not attempt to re-identify de-identified data, except as permitted or required by law.
3. SOURCES OF INFORMATION
We collect personal information about you directly and indirectly, including from the following sources:
We collect personal information directly from you. For example, we collect Contact Information, Demographic Information, and Location Information if you enter a promotion. We collect Contact Information if you sign up for our email newsletter or create an account on certain of our Platforms. We collect Payment Information and Purchase and Preference Information if you make a purchase. We collect Contact Information and Employment-Related Information if you apply for a job. We also collect any personal information you provide if you make a request or contact us.
We collect personal information from you and your devices passively. We use tracking tools like browser cookies, web beacons, pixels, and tags to automatically collect information about you (including Internet and Network Activity Information, Demographic Information, Purchase and Preference Information, Inferences, and Location Information). Our advertising technology partners and analytics providers may also provide us with this information through these tools. We collect this information when you interact with our Platforms, our ads, or our emails that we or vendors send to you.
We receive personal information from vendors we hire to work on our behalf. For example, vendors that host or maintain our Platforms, help us fulfill purchases, and send emails for us may give us Contact Information, Demographic Information, Internet and Network Activity Information, Location Information, Payment Information, Purchase and Preference Information, and Inferences. Our employment and recruiting vendors give us Contact Information and Employment-Related Information. Our marketing agencies may also provide us with Contact Information, Demographic Information, Internet and Network Activity Information, Location Information, Payment Information, Purchase and Preference Information, and Inferences.
We may receive information about you from other sources, including third parties. For example, if you are on another website and you opt-in to receive information from us, that website will submit to us your Contact Information and other personal information you provide so that we may contact you as requested. You may also choose to participate in a third party application or feature (such as one of our Facebook or Twitter applications or a similar application or feature on a third party website) through which you allow us to collect (or the third party to share) information about you, including Contact Information, Internet and Network Activity Information, Location Information, and other information such as lists of your friends, “likes”, comments you have shared, and groups. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third party website or interactive service.
We may combine information. We may supplement the information we collect about you through the Platforms with information from third parties in order to enhance our ability to serve you, to tailor our content to you and/or to offer you opportunities to purchase products or services that we believe may be of interest to you.
4. SHARING OF INFORMATION
We may share non-personal information, such as aggregate data and Usage Information with third parties. We may also share your information as disclosed at the time you provide your information, as set forth in this Privacy Notice and in the following circumstances:
We may share each category of personal information within the Bimbo Bakeries family of companies. This includes our subsidiaries, affiliates, and brands.
Vendors Providing Services On Our Behalf. We may share each category of personal information with vendors that perform functions on our behalf such as service providers that host or operate our Platforms, analyze data, or provide customer service; and agencies that administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance.
Business Partners and Marketing Companies. We may share Contact Information, Internet and Network Activity Information, Demographic Information, Purchase and Preference Information, Inferences, and Location Information with our sponsors, partners, advertisers or other third parties to provide you with product information and promotional and other offers. These third parties may co-sponsor or participate in our promotions, contests, and sweepstakes. These may be “powered by” partners or our partners on co-branded sites. We may also share the above categories of personal information with companies that help us with our marketing efforts, including social media platforms, advertising networks, data brokers, analytics companies, and ad tech companies. Some transfers of your personal information to our business partners and marketing companies may be viewed as a “sale” or “sharing” under certain state laws. To learn about your choices for these communications, read the “Your Privacy Rights, Choice and Access” section and the “Advertising/Behavioral Targeting; How to Opt Out” section, below.
With A Successor To All Or Part Of Our Business. In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, any or all categories of personal information may be sold or transferred as part of that transaction. We may also share personal information with others as they conduct due diligence as part of our corporate changes.
We may share personal information for other reasons we may describe to you from time to time, with your consent, or as permitted or required by law. We may share de-identified or aggregated data for any purpose, unless prohibited by law.
5. YOUR PRIVACY RIGHTS, CHOICE AND ACCESS.
You can opt out of our marketing. You may always direct us not to share your personal information with third parties for marketing purposes, not to use your personal information to provide you with information or offers, or not to send you newsletters, emails or other communications by: (i) sending us an email at [email protected]; (ii) calling us at 1-800-984-0989; or (iii) following the “unsubscribe” or removal instructions in the communication that you receive. Your opt-out request will be processed within 30 days of the date on which we receive it.
You can control certain cookies and tracking tools we use. For details, see the “Advertising/Behavioral Targeting; How to Opt Out” section below.
You can make certain requests.
- If you wish to modify, verify, correct, or delete any of your personal information collected through the Platforms, you (or your authorized agent) may contact us by email at [email protected], by calling us at 1-800-984-0989. You can also submit a deletion request here. In accordance with our routine record keeping, we may delete certain records that contain personal information you have submitted through the Platforms. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information. It may not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. We will retain your information for as long as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at the above telephone number or email. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Residents of certain US states can ask for access to their personal information. If you live in California, Colorado, Connecticut, Utah, or Virginia, you (or your authorized agent) can send us requests to access your personal information. We will provide access to your personal information in a portable and (to the extent technically feasible) a readily usable format. You can also request to confirm the processing of your personal information and request to revoke your prior consent. To do so, contact us by email at [email protected], call us at 1-800-984-0989, or use our web form here.
- Residents of certain US states can appeal our decisions. If you live in Colorado, Connecticut, and Virginia, you can appeal our decision if you are not satisfied with the outcome of your request. Please send appeals by email to [email protected] with “Attention: Privacy Appeal” in the subject line.
- Additional information: We will use commercially reasonable efforts to honor your request in accordance with applicable law, and we will verify your identity by email. If you have an authorized agent submit a request on your behalf, we may still verify your identity and their authority to submit a request for you. We will not discriminate against you for exercising any of the rights outlined in this Privacy Notice. We currently process certain requests from our business contacts only if they reside in California. California residents can also view additional information about their rights and our notice at collection below.
Your California Privacy Rights
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at [email protected], call us at 1-800-984-0989, or write to us at Bimbo Bakeries USA, Consumer Relations Department, P.O. Box 976, Horsham, PA 19044. Indicate in your letter or email subject line that you are a California resident making a “Shine the Light” inquiry.
If you reside in California, you have the right to make the following more specific requests with respect to your personal information. We will not discriminate against you for making any of these requests.
- Know / Access – You have the right to request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we sold or disclosed, our business or commercial purpose for collecting, selling, or sharing the personal information, the categories of third parties to whom we disclosed the personal information, and the specific pieces of personal information we collected about you.
- Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
- Correction – You can ask us to correct inaccurate personal information that we maintain about you.
- Opt-out – You can request to opt-out of the sale or sharing of your personal information by visiting our Do Not Sell or Share My Personal Information page. For purposes of this Privacy Notice, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration, and “sharing” means any disclosure of personal information (renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means) to third parties for cross-contextual behavioral advertising purposes; in each case, subject to certain exceptions under California law. Your selections are specific to the device, website, and browser you are using, and are deleted whenever you clear your browser’s cache.
- Financial Incentives – From time to time, we may offer financial incentives in connection with the collection or use of personal information. The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by emailing us at [email protected].
Additional information: California residents can exercise these rights by emailing us at [email protected], by calling us at 1-800-984-0989, or by clicking the following links: for an access request, click here; for a deletion request, click here; and to opt out of sale, click here. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate consumer requests. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.
Additional disclosures: For purposes of exercising these rights, please note the following regarding how we collect and use your personal information as described in this Privacy Notice:
- We may collect and use, for our business and commercial purposes, the following categories of personal information as set forth in applicable California law: Identifiers; payment information; Internet or other electronic network activity information; demographic information; characteristics of protected classifications under California or federal law; commercial information; professional or employment information; inferences; and geolocation data. For more information, see Section 1.
- We collect and use these categories of personal information for the business and commercial purposes described in Section 2 of this Privacy Notice. We collect these categories of personal information from the sources described in Section 3 of this Privacy Notice. To the extent permitted by applicable law, we may disclose these categories of personal information for the business and commercial purposes described in Section 2 of this Privacy Notice to the categories of third parties described in Section 4 of this Privacy Notice.
- We may “sell” or “share” the following categories of personal information: Identifiers; Internet or other electronic network activity; demographic information; commercial information; inferences; and geolocation data. California law defines “sell” and “sharing” broadly. Certain sharing of information might qualify as a “sale” or “sharing” under California law, even if the information is not exchanged for money. We may “sell” or “share” these categories of personal information to the social media platforms, advertising networks, analytics companies, and ad tech companies described in Sections 4 and 6 of this Privacy Notice (to the extent permitted by applicable law).
6. ADVERTISING/BEHAVIORAL TARGETING; HOW TO OPT-OUT.
We and our third-party advertising partners display targeted advertising, cross-context behavioral advertising, and interest-based advertising using information from cookies and tracking tools and inferences gathered about you over time and across websites, apps, or other platforms. These ads can be served on websites, on social media, in apps, and in emails. The ads may be based on your browsing habits, purchases, location, or online activities. The ads can be about our products or other companies’ products and services. We and our third-party partners gather information about you for this purpose from the cookies, pixels, tags, web beacons, and other tracking tools described in this Privacy Notice. Our partners might also link your name or email address to other information they collect.
As part of these practices, we also share information with third-party advertising partners though tracking tools on our Sites. These third-party partners include social media platforms, analytics companies, data brokers, and third-party advertisers. Personal information received by these third parties is also subject to their privacy policies. These third parties can share your information with others and use the information for their own marketing purposes or the marketing purposes of others. This may include the delivery of targeted advertising, cross-context behavioral advertising, and interest-based advertising. We do not control certain privacy settings and preferences maintained by our social media platform partners like Facebook and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media platform.
You can opt-out of sale / targeted advertising on our Platforms. You can opt out of the “sale” of your personal information, as well as certain types of “targeted advertising” on our Site (as these terms are defined under applicable laws and as described in this Privacy Notice). Your request will be processed and fulfilled in accordance with applicable laws. To make a request, click Do Not Sell or Share My Personal Information here, or in the footer of our Platforms.
You can control certain cookies and tracking tools. Your browser or device may give you the ability to control cookies or other tracking tools. How you do so depends on the browser. To control flash cookies, you can go here. Why? Because flash cookies cannot be controlled through your browser settings. The Digital Advertising Alliance also offers tools to opt out of certain interest-based advertising by visiting optout.aboutads.info and optout.privacyrights.info. If you block or reject cookies and tracking tools, certain features on our Platforms may not work, and not all of the tracking describe in this Notice will stop.
Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. We will respond to opt-out preference signals to the extent required by law for your browser or device (such as Global Privacy Control, https://globalprivacycontrol.org/), but we cannot link this information to your account and we do not respond to “do not track” signals. Your selections are specific to the device, website, and browser you are using, and are deleted whenever you clear your browser’s cache.
Google Analytics: Our platforms use Google Analytics, including certain advertising features to better understand our users, create audiences for our ads, and to evaluate and improve our platforms. For more information on how to opt out for these tools, please visit https://tools.google.com/dlpage/gaoptout and http://www.google.com/safetycenter/tools/#manage-your-ads-preferences
The Platforms are not directed to children under 16. We do not knowingly collect, use, sell, share, or disclose personally identifiable information from anyone under 16 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her personal information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 16, we will make reasonable efforts to delete such information from our records.
8. SECURITY AND RETENTION OF YOUR INFORMATION.
We take information security seriously and use certain reasonable security measures to help protect your personal information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us with your information at your own risk.
We will retain information for as long as it is reasonably needed or permitted in light of the purposes for which we collected it. We also retain information as required by law. The criteria we use to determine our retention policies include the length of our relationship with you, your requests, your continued use of our Platforms, ongoing obligations such as contracts and services, and our legal obligations.
9. OTHER SITES.
The Platforms may contain links to other sites that we do not own or operate. This includes links from advertisers, sponsors and/or partners that may use our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies to your device, they may independently collect data or solicit personal information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Platforms (including those linked to through an email or social networking page).
The Platforms may make available chat rooms, forums, message boards, and news groups. Remember that any information that you disclose in these areas becomes public information and is not subject to the provisions of this Privacy Notice.
10. CONSENT TO PROCESSING AND TRANSFER OF INFORMATION.
The Platforms are governed by and operated in, and in accordance with the laws of the United States. We make no representation that the Platforms are governed by or operated in accordance with the laws of any other nation. Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are located in Mexico, the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Platforms, or providing us with any information, you (a) acknowledge that the Platforms are subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.
We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes we will notify you by either email (sent to the e-mail address you have provided) or by means of a notice on our Platforms prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
12. CONTACT US
If you have any questions or concerns about this Privacy Notice, the practices of the Platforms, or your experiences with the Platforms, please contact us at [email protected].