Privacy Policy

VISTA HORTICULTURAL GROUP INC. PRIVACY POLICY

Last Updated: September 10, 2024

Our company includes different brands. When you visit, shop, create an account with us, or use our websites and applications, your information is controlled by Vista Horticultural Group Inc. and its affiliates (“Company,” “we,” or “us”). We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (this “Policy”). Please read this Policy carefully to understand our policies and practices for collecting, using, maintaining, protecting, and disclosing your information. If you do not agree with our policies and practices, your choice is not visit, register with, access, use, or otherwise engage (collectively, “interact”) with us. By interacting with this website or otherwise contacting us, you agree to this Policy.

This Policy describes the types of information we may collect from you or that you may provide when you:

Interact with the websites at edenbrothers.com, www.bulkseedstore.com, www.bulkwildflowers.com, and/or www.flowerbulbfarm.com (collectively, our “Websites”).
Inquire about or participate in events we conduct, including contests and sweepstakes (each an “Event” and collectively, our “Events”).
Email, text, call, or otherwise communicate with us, including through our social media pages (your “Communications”).
Interact with our pages or accounts on social media platforms (our “Social Media”), including when you view or click on posts or links, such as those related to our Events.
Apply for employment with us (“Applicants”), including through Career Place (a candidate screening platform provided by our third-party services provider, MDG2 Technologies, Inc.) or go through the process of becoming employed with us (“Employees”).
Apply for and engage in our Eden Brothers Affiliate Program (the “Affiliate Program”).

Our Websites, together with the content, products, and services we provide, are collectively referred to herein as our “Services.”

We may provide additional privacy notices specific to certain practices or regions. Those terms are to be read in conjunction with this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Websites after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

Children Under the Age of 18

Our Services are not for children. No one under 18 is permitted to provide any information on our Websites. We do not knowingly collect information from children. If you are under 18, do not use our Websites or provide any information. This includes registering, using interactive features, or giving us your name, address, phone number, email, or username. If we find out we have collected information from a child under 18, we will delete it. If you think we might have information from or about a child under 18, please email us at service@edenbrothers.com, call us at (855) 440-2929, or fill out our electronic contact form here.

Information We Collect & How We Collect It

We collect two basic types of information:

Information that identifies (whether directly or indirectly) a particular individual, such as your name, postal address, email address, and telephone number (“Personal Information”); and
Information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual (“Anonymous Information”). When Anonymous Information is directly or indirectly associated with Personal Information, the resulting information is also treated as Personal Information.

We may use Personal Information and Anonymous Information to create a third type of information: information about groups or categories of individuals, which does not identify and cannot reasonably be used to identify an individual (“Aggregate Information”).

In particular, we collect:

Contact information you provide when you request information, sign-up for our newsletter, create an account, participate in an Event, apply for our Affiliate Program, or otherwise contact us (including through our Social Media), such as your name, email address, telephone number, social media account handles, and address of residency.

Transaction information you provide when you request information, contact us, or purchase, return, request, or exchange a product or service from us, such as your postal address, telephone number, and payment information.
Information you voluntarily upload on our Websites or on our Social Media, such as your product reviews, photos, contest submissions, and comments (your “User Uploads”). If you provide Personal Information in your User Uploads, that Personal Information may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party.
Location information, including your zip code (optional) during sign-up and your address at the time of purchase. While we track IP addresses, they are not a reliable source of location information. Primarily, we use self-reported zip codes to determine USDA growing zones, allowing us to provide relevant content and regional product suggestions. This information may also include precise location data provided by a mobile or other device accessing our Websites or associated with your IP address or other online or device identifiers.

Activity, usage, viewing, technical, and device data when you visit our Websites, or open emails we send. This includes the content you view, how often you use our Websites, your browser or device type, unique device identifier, and IP address. We may obtain this information from a third party, such as a site or platform provider.
Copies of your Communications, including call recordings when you call our customer service lines.

How We Collect Your Information

We may collect information from you in the following ways:

Directly From You. We collect information you provide to us when you request or purchase products, services, or information from us, register with us, submit or post User Uploads, respond to surveys, call our customer service phone number(s), or otherwise interact with us using one or more devices.
Through Automatic Technologies. We collect information through a variety of technologies, such as cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our Websites, whether or not you are logged in or registered. Please see Automatic Technologies We Use for further information and Your Controls and Choices for information about how we respond to Do Not Track signals and how to disable cookies or otherwise make choices with respect to such data collection.
From Third Parties Service Providers. We acquire information from other third parties to update or supplement the information you provided, or we collected automatically. This includes information related to our Affiliate Program. Applicable law may require that you authorize the third party to share you information with us before we can acquire it.

From Social Media. When you engage with our Social Media, we may collect information such as your social media handle and public profile information, including your friend list if your profile is public. Interactions on our posts do not provide us access to your email address, real name, browsing history, or preferences.

Automatic Technologies We Use

The technologies we use to automatically collect your information when you interact with our Websites include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Cookies may collect data such as your IP address, browser type, operating system, referring URLs, access times, and your activity on our Websites, including the pages you visit and the links you click. 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 Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites.
Click Tracking. Click tracking is an analytical feature that measures and reports where users click or tap on our Websites. Every time you click on our Websites, we record the event and log your user session for future analysis. We use this information only to improve our Services. Click tracking only collects the IP address assigned to you on the date when you visit our Websites, which we may combine and store with other Personal Information we have about you.
Analytics. We collect analytics information from third-party service providers, such as Google, Microsoft, and Klaviyo, through server-side tracking. This includes information about your interaction(s) with our Websites and advertising campaigns. This includes what pages you visit and when, what sites you visited prior to coming to our Websites, and your IP address. We use the customer engagement information we get from analytics tools only to improve our Services and may combine the information collected this way with other Personal Information we may have about you.
Business Intelligence and Lead Generation Tools. We use business intelligence tools, such as Klaviyo, Google Analytics, and Microsoft Power BI, to identify and analyze your visits to our Websites and your engagement with our advertising campaigns, through server-side tracking. These tools collect data about your interactions with us, your visits to our Websites, your engagement with our emails, and the performance of our advertising campaigns. This information helps us understand your behavior and preferences and allows us to tailor our marketing strategies. We also use Performance Horizon Inc trading as Partnerize, who provides us with Ascend by Partnerize (“Partnerize”) for our Affiliate Program, to track and manage affiliate marketing activities, including clicks, conversions, and purchase history. The data collected is used to optimize our marketing efforts, improve your engagement, and drive business growth. We use the information we get from these tools only to improve our Services and do not combine the information collected with other Personal Information we may have about you.
E-Commerce Platforms. We use e-commerce platforms, such as Shopify, to manage our online store and facilitate transactions through server-side tracking. These platforms collect data such as your purchase history, product preferences, and browsing behavior on our Websites. This information helps us understand your purchasing patterns and preferences and allows us to improve our product offerings and customer service. The data collected is used to streamline your shopping experience, manage inventory, and enhance your overall satisfaction. We may combine the information collected with other Personal Information we may have about you.

We use the following third-party tracking tools in connection with our Website:

Klaviyo. Klaviyo tracks users’ on-site behavior and ties it back to a detailed user profile that includes purchase history, browsing activity, click patterns, and communication interactions. This comprehensive data collection allows us to build targeted and personalized marketing communications based on customers’ preferences, behaviors, and actions. By understanding how users interact with our Website, we can send more relevant emails, tailor our marketing campaigns, and improve the overall customer experience. We also use Klaviyo's insights to segment our audience and deliver content that aligns with their interests. While we utilize Klaviyo’s tracking capabilities to enhance our marketing efforts, we do not control Klaviyo’s tracking technologies or how Klaviyo may use the data. Klaviyo’s ability to use and share information collected about your visits to our Website is governed by Klaviyo’s Terms of Use and Privacy Policy. If you have any questions about how Klaviyo uses your information, please contact Klaviyo directly.
Partnerize. Partnerize uses tracking codes and tags on our Websites to collect data about your interactions, such as clicks, conversions, and purchase history. These tracking technologies help us understand the performance of our Affiliate Program. The data collected by Partnerize is used to attribute sales or leads to the correct publishers and optimize our marketing efforts. We do not control Partnerize’s tracking technologies or how Partnerize may use them. Partnerize’s ability to use and share information collected about your visits to our Website is governed by Partnerize’s Terms of Use and Privacy Policy. If you have any questions about how Partnerize uses your information, please contact Partnerize directly.

How We Use Your Information

Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you to:

Present out Websites and their contents to you.
Provide you with the experiences, products, and services you request, view, engage with, or purchase.
Communicate with you about your account or transactions with us and send you information or request feedback about features on our Websites and or changes to our policies.
Send you offers and promotions for our products and services.
Personalize your content and experiences, including by recognizing you when you return to our Websites and storing information about your preferences.
Provide you with targeted advertising based on your activity on our Websites and on third-party sites and applications. See Online Tracking Technologies and Advertising to learn more about how we use your information for personalization and tracking.
Operate, understand, optimize, develop, or improve our Services and operations including our Affiliate Program.
Detect, investigate, and prevent activities that may violate our policies, pose safety issues, or be fraudulent or illegal.
Notify you of product recalls or safety issues.
Fulfill the purpose for which you provided the information, or any other purpose described at the time of collection, or for another purpose with your consent.

How We Share Your Information

We will not share your Personal Information with a third party except in limited circumstances, including:

When we work with service providers performing services on our behalf; however, these companies are prohibited from using your Personal Information for purposes other than those requested by us or required by law.
- Contact information with our email marketing services provider to manage newsletter sign-ups and email communications, our order management system to fulfill orders, Career Place to manage employment applications and communication with Applicants, transaction processes to securely process payments, and Shopify to facilitate purchases, manage customer accounts, and provide customer support. This information may also be used by analytics and business intelligence platforms to generate customer insights and visualizations.
- Purchase information with our payment processors to process your purchases on Shopify, to facilitate purchases, manage customer accounts, process transaction information, track and manage inventory, generate sales reports and analytics, create data visualizations and business intelligence reports, ensure compliance with legal and financial regulations, and provide customer support, and our order management system to track and manage order fulfillment and generate analytics and data visualization reports.
- Payment information with our payment processors to process and facilitate your purchases. We do not ever see this information; our third-party payment processors exclusively handled this information.
- User Uploads with review management platforms to display reviews, customer service platforms to handle inquiries, and marketing platforms to showcase testimonials and photos, enhancing our product offerings and customer experience. User-generated content may also be analyzed and visualized to improve customer engagement strategies.
- Location information, namely IP address and zip code with our email marketing services provider to provide relevant content and regional product suggestions based on your location. Location data may also be visualized to assess geographic trends and regional performance.
- Activity, usage, viewing, technical, and device data with our analytics companies and email marketing services provider to understand how you interact with our emails and Websites, our web hosting provider to ensure the proper functioning of our Websites, our e-commerce platform provider to process transactions and manage your shopping experience, Partnerize to track and attribute sales in our Affiliate Program, and with our transaction processors to securely handle payments. These data types may be further processed by analytics and business intelligence platforms to generate visual reports and usage insights. Additionally, site activity data is shared with Meta/Facebook for retargeting purposes if you are simultaneously logged into both Facebook and one of our Websites via your browser.
- Applicant and Employee data with Career Place to facilitate the employment application process. Applicant and Employee data may also be analyzed and visualized for HR management and workforce analytics.
When we provide you with relevant advertising on third-party Websites and applications, we may share limited Personal Information about you such as certain identifiers or hashed email address, with third parties. To learn more about how we use your information for personalization and tracking, please visit Online Tracking Technologies and Advertising.
When we share your Personal Information with third parties in connection with the sale of a business, to enforce our Terms of Use, to ensure the safety and security of our users, customers, employees, and/or other third parties, to protect our rights and property and the rights and property of our users, customers, employees, and/or other third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.

Please note that, except as otherwise stated above, once we share your Personal Information with another company in the above circumstances, the information received by the other company is controlled by that company and becomes subject to its privacy practices.

Your Controls and Choices

Collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include:

Correcting, updating, and deleting your customer account.
Choosing or changing your choices for subscriptions, newsletters, alerts, or other notifications.
Setting your browser to transmit “Do Not Track” signals. However, since uniform standards for “Do Not Track” signals have not been adopted, our Websites do not process or respond to such signals.
Choosing whether to receive from us offers and promotions for our products and services we think may be of interest to you.
Controlling targeted advertising by clicking on “Do Not Sell or Share My Personal Information” in the footers of our Websites.
Requesting removal of your Personal Information from a public forum on our Websites or Social Media.
Requesting access to the Personal Information we hold about you and that we amend or delete it.
Opting out of Google Analytics by following Google’s instructions at https://tools.google.com/dlpage/gaoptout.
Controlling targeted advertising from many ad networks and partners, data exchanges, and marketing analytics and digital advertising and marketing service providers (by visiting the Digital Advertising Alliance or the Network Advertising Initiative).

You may exercise these controls and choices in various ways, including as outlined above, by emailing us at service@edenbrothers.com, calling us at (855) 440-2929, filling out our electronic contact form here, or by following instructions provided in communications sent to you. You can also opt out of targeted or interest-based ads by visiting the Digital Advertising Alliance or European Interactive Digital Advertising Alliance or using the opt-out mechanism in the “Interest Based Ads” link in the footer of the site you are visiting.

Please be aware that if you do not allow us to collect Personal Information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of Personal Information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific Personal Information about you that we process or retain, and your rights regarding that Personal Information, please email us at service@edenbrothers.com, call us at (855) 440-2929, or fill out our electronic contact form here.

Data Security, Integrity, and Retention

The security, integrity, and confidentiality of your information are very important to us. We have implemented technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods.

As part of our commitment to safeguarding your privacy, we are implementing server-side tracking. This means that instead of relying on third-party scripts and cookies that run on your device, we process data directly on our secure servers. Server-side tracking enhances your privacy by reducing the exposure of your information to potential vulnerabilities on your device and limiting third-party access. By handling data on our servers, we maintain greater control over its security and ensure that it is protected by our security measures.

Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Online Tracking Technologies and Advertising

We, including through advertising, marketing, or audience measurement service providers, operating on our behalf, may collect information about your activity, or activity on devices associated with you, on our Websites using tracking technologies such as cookies, pixels, tags, software development kits, application program interfaces, and Web beacons. We may collect information whether or not you are logged in or registered and may associate this tracking data with your account (if you have one).

Definitions for some of the tracking technologies listed, as well as information about your choices with respect to them, are available below. This tracking data may be used for many purposes including, for example, to:

Provide useful features to simplify your experience when you return to our Websites (for example, remembering your shipping information for future purchases).
Deliver relevant content and advertising based on your preferences, usage patterns and location.
Monitor, evaluate, measure, and optimize the use and operation of our Websites and the advertising that you see.
Analyze traffic on our sites and on the sites of third parties (such as Amazon and social media platforms).

We may use your Personal Information to deliver relevant marketing and advertising to you on our properties and on third parties’ sites and applications. We may provide social media and other platforms with limited Personal Information, such as certain identifiers or your hashed email address, which they match with their customers’ profiles. Based on this, the platform may show you our ads, look for other users who may enjoy our ads, suppress our ads for you, and provide us insights on how to optimize and better target our advertising.

Some states provide residents or, in some cases, their authorized agents, with the right to opt out of the “selling” or “sharing” of their “personal information”, or of “targeted advertising” based on their “personal information.” To submit a request to opt out you may click the “Do Not Sell or Share My Personal Information” link in the footers of our Website. Please note that your opt-out choice is specific to the Website and to the device and browser you are using. If you access other digital properties of ours, you will need to make a separate election for each. Also, if you clear your cookies on your browser or use another browser or device, you may need to opt out again. Importantly, you may also choose to email us at service@edenbrothers.com, call us at (855) 440-2929, or fill out our electronic contact form here, which may enable us to take action on your opt-out request more broadly than for a specific Website.

You may also choose to opt-out of targeted advertising directly with many ad networks and partners, data exchanges, and marketing analytics and other digital advertising and marketing service providers. You may also be able to choose to control targeted advertising on other websites and platforms that you visit. In addition, you may choose to control targeted advertising you receive within applications by using the settings and controls on your devices.

Examples of online tracking technologies include:

Cookies. Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use cookies to bring together information we collect about you. You can choose to have your computer warn you each time a cookie is being placed on your device, or you can choose to block all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that make your guest experience more efficient, and some of our Services will not function properly.
Web beacons and marketing pixels. Web beacons and marketing pixels are small pieces of data that are embedded in images on the pages of sites. They may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use web beacons or marketing pixels to bring together information we collect about you.

Data Transfers, Storage, and Processing

Wherever your Personal Information is transferred, stored, or processed, we will take reasonable steps to safeguard the privacy of your Personal Information. These steps may include standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring Personal Information

Changes to this Policy

From time to time, we may change this Policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our Websites or by other means, consistent with applicable law.

U.S. Residents’ Rights

Notice to US Residents: If you are a US Resident, you may have certain additional privacy rights. Please visit our US State Privacy Rights page for more information.

Comments and Questions

If you have a comment or question about this Policy, please email us at service@edenbrothers.com or call us at (855) 440-2929, or fill out our electronic contact form here.

VISTA HORTICULTURAL GROUP INC. U.S. STATE PRIVACY RIGHTS

Last Updated/Reviewed: August 12, 2024

This Privacy Notice for U.S. Residents (this “Notice”) supplements the information contained in the Vista Horticultural Group Inc. (“Company,” “we,” or “us”) Privacy Policy and applies solely to residents of certain U.S. states that have their own data privacy laws and regulations, and associated rights. Please read this Notice in conjunction with our Privacy Policy.

CALIFORNIA

We adopt this section of this Notice to comply with the required “Notice at Collection” disclosures under California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”) (together, the “California Privacy Laws”). This section applies to California consumers, including employees, job applicants, and contractors (“you”). Any terms defined in the California Privacy Laws have the same meaning when used in this section of this Notice.

Notice at Collection

We may collect or receive (and may have collected or received during the 12-month period prior to the Last Updated date of this Notice) the categories of personal information listed below. Not all categories will be collected or received for every individual.

Identifiers and customer records personal information, such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, name, signature, physical characteristics or description, telephone number, state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of protected classifications and demographic information only if voluntarily provided, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, and veteran or military status.
Commercial information, including information about your interests and consuming history or tendencies, such as products or services considered, purchased, obtained, or other purchasing or consuming histories or tendencies; transaction information when you request information, contact us, or purchase, return, request, or exchange a product or service, including payment card information or other financial information; information provided in response to surveys or other research conducted on our behalf; and information you provide in public forums.
Internet or other electronic network activity information, including information regarding your interactions with us on our Websites, including browsing history, search history, and other information about your interactions with our websites or advertisements, and information we obtain from third parties about your interactions with us online.
Geolocation data, including precise or approximate location information provided by a mobile device or other device or product interacting with or detected by our websites, where we are permitted by law to process this information.
Sensory data, including audio, electronic, or similar information, including telephone call recordings.
Professional or employment-related information if you apply for employment or go through the process of becoming employed with us, such as current or past job history or performance evaluations.
Inferences based on the above, including creating profiles reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and/or aptitudes.
Sensitive Personal Information, such as government-issued identifiers including social security number, driver’s license, state identification card, or passport number (if you apply for employment or go through the process of becoming employe with us), account log-in and financial information (such as payment card details), and precise geolocation.

We may obtain and combine personal information from different sources, as described in the How Do We Collect Your Information section of our Privacy Policy. We collect this information so that we can best serve you, including to fulfill your requests and to share offers or information that we think you may be interested in. As further described in the “How We Use Your Information” section in our Privacy Policy, we generally collect and use the above-listed categories of personal information to provide and manage our website, products, and services, and for other business or commercial purposes, such as advertising, marketing, and to improve our products and services.

How We Use Sensitive Personal Information

We use sensitive personal information for the following purposes:

Employee and Applicant-Specific Purposes:

To confirm the identity of an applicant or employee using government-issued identifiers (e.g., social security number, driver’s license, state identification card, or passport number).
To conduct pre-employment background checks, including criminal history, credit checks, and employment verification, using social security numbers and other identification details.
To manage payroll activities, including salary payments, tax withholdings, and benefits administration, using social security numbers and financial information.
To enroll and manage employee benefits such as health insurance, retirement plans, and other company-provided benefits.
To comply with federal, state, and local employment laws and regulations, including reporting and tax obligations.
To secure access to company systems and physical locations by using account log-in details and ensuring that sensitive areas are accessible only to authorized personnel.
To book and manage business travel for employees using personal identification information and payment card details.
To process and reimburse business-related expenses for employees, using financial information like payment card details.

General Purposes (Applicable to Everyone):

To detect and prevent fraud, unauthorized transactions, and other malicious activities by verifying the authenticity of financial transactions using payment card details and account information.
To make inferences about consumers.
To promote region-specific products and services using precise geolocation data.

Selling and Sharing of Personal Information

We do not rent or sell the personal information we collected. However, certain data collection on our websites for purposes of interest-based advertising and social media tools may be a “sharing” under the California Privacy Laws. As defined by California Privacy Laws, we have “shared” certain data elements with our advertising, marketing, and audience measurement service providers for “targeting advertising” as described in the Online Tracking Technologies and Advertising section in our Privacy Policy The shared data falls within the following categories of personal information:

Internet or other electronic network activity information, namely, website activity such as browsing history and time spent.

We do not knowingly share the personal information of consumers under 16 years of age. For more information about treatment of children’s personal information, see the Children Under the Age of 18 section of our Privacy Policy.

If you would like to opt out of the sharing of your personal information, you may click the “Do Not Sell or Share My Personal Information” link in our website footers or in our application settings. Please note that your opt-out choice is specific to the websites and to the device and browser you are using. You may additionally choose to email us at service@edenbrothers.com, call us at (855) 440-2929, or fill out our electronic contact form here, which may enable us to take action on your opt-out request more broadly than for a specific website.

Data Retention

We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in our Privacy Policy, including to satisfy legal or reporting requirements. What this means in practice will vary for different types of information, but the criteria assessed in the data retention analysis consider ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.

Your California Privacy Rights

If you are a California resident, you can make certain requests regarding your personal information. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial. Your rights include:

Right to Know: You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purposes, and the categories of third parties with whom such personal information is shared.
Right to Access: You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.
Right to Delete: You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.
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” to or with “third parties” (as those terms are defined by California Privacy Laws).
Right Not to Receive Discriminatory Treatment. You have the right not to receive discriminatory treatment for the exercise of your privacy rights. If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those differences are reasonably related to your information. For example, if you exercise your right to opt out of “sale” or “sharing” of your “personal information,” the ads you view may not be tailored to your interests. However, we may offer you certain financial incentives permitted by the California Privacy Laws that can result in different prices, rates, or quality levels. Any California Privacy Laws-permitted financial incentive we offer will reasonably relate to your personal information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. For more information about our financial incentive programs, please see Notice of Financial Incentives below.

Exercising Your California Privacy Rights

Making Requests to Know, Access, Delete, or Correct Your Personal Information. To exercise your rights to know, access, delete, or correct your personal information, please submit a request by emailing us at service@edenbrothers.com, calling us at (855) 440-2929, or filling out our electronic contact form here. Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may only submit a request to know twice within a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a request to review and comply with the request. You do not need to create an account with us to submit a request to know or delete. We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will delete or de-identify personal information not subject to a legal exception from our records and will direct our service providers to take similar action. For data portability requests, we 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.
Instructions for Using an Authorized Agent to Make Requests: You may use an authorized agent to submit a request to know or an access, deletion, correction, or opt-out request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests by emailing us at service@edenbrothers.com.

Notice Of Financial Incentives

We may provide special offers or discounts to you as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when you sign up to receive marketing messages or when you claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the “Programs.”

In general, we collect personal information to support and fulfill the Programs, which could include identifiers, Internet or other electronic network activity information, geolocation data, and inferences drawn from the above. For additional details on the types of information we may collect, please see Types of Information We Collect in our Privacy Policy. Because we collect personal information, the Programs may be considered to be “financial incentives” or “price or service differences” under California law.

To the extent the Programs are reasonably related to the value of your personal information, the method for calculating this value would include the expenses related to our offer (such as the costs of providing discounts, free shipping, or other promotions, intellectual property or marketing costs, and other related expenses). The value of your personal information that we collect will vary depending on your engagement.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect and use your information, our Privacy Policy, your choices and rights regarding such use, or wish to exercise Your California Privacy Rights, please do not hesitate to email us at service@edenbrothers.com.

NEVADA

Nevada’s privacy law, known as Senate Bill 220, provides Nevada residents with a limited right to opt-out of certain personal information sales. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

TEXAS

We adopt this section of this Notice to give Texas residents (“you”) additional information required by the Texas Data Privacy and Security Act (the “TXDPSA”). This section applies to you when you are acting in an individual or household context, but not when you are acting in a commercial or employment context, including as a job applicant. Any terms defined in the TXDPSA have the same meaning when used in this section of this Notice.

Collection, Use, and Sharing of Your Personal Data

We do not rent or sell the personal information we collected. We may disclose your personal information to our third-party service providers for a business purpose as described in the How We Share Your Information section in our Privacy Policy. This includes sharing information with our advertising, marketing, and audience measurement service providers for “targeted advertising”, as described in the Online Tracking Technologies and Advertising section in our Privacy Policy. We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers, as defined in the TXDPSA. We do not knowingly process personal data from children under the age of 13. For more information about treatment of children’s personal information, see the Children Under the Age of 18 section of our Privacy Policy.

Your Texas Privacy Rights

If you are a Texas resident, you can make certain requests regarding your personal data. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the data applies. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial. Your rights include:

Right to Know: You have the right to know whether we control the collection of your personal data.
Right to Access: You have the right see what personal data we have collected about you in a usable format.
Right to Delete: You have the right to request that we delete personal data that we collect from you, subject to applicable legal exceptions.
Right to Correct: You have the right to request that we correct inaccurate personal data.
Right to Opt-Out of Sale of Personal Data and Targeted Advertising: You have the right to “opt out” of “targeted advertising,” certain types of profiling, and the “sale” of your “personal data” (as defined in the TXDPSA).

Exercising Your Texas Privacy Rights

Making Requests to Know, Access, or Delete Your Personal Information. To exercise your rights to know, access, delete, or correct your personal data, please submit a request by emailing us at service@edenbrothers.com, calling us at (855) 440-2929, or filling out our electronic contact form here. Only you, or someone legally authorized to act on your behalf, may make a request related to your personal data. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. We will only use personal data provided in a request to review and comply with the request. You do not need to create an account with us to submit a request to know or delete. We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will delete or de-identify personal data not subject to a legal exception from our records and will direct our service providers to take similar action. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the data from one entity to another entity without hindrance.
Instructions for Using an Authorized Agent to Make Requests: You may use an authorized agent to submit a request to know or an access, deletion, correction, or opt-out request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests by email us at service@edenbrothers.com.

How to Submit an Appeal

To appeal our decision regarding a request to these rights, you may email us at service@edenbrothers.com.