PP - Introduction Privacy Policy Compass USA and our family of companies (“Compass USA”, “we”, “our”) respect your right to the security and privacy of your data. This Privacy Policy describes who we are and how we collect, share, and use personal information about you. This Privacy Policy applies to information collected through our corporate Website at www.Compass-usa.com or one of our affiliated websites or a mobile application provided by Compass or one of our member companies (the “Website”). If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this page. PP - What do we do? What do we do? We are a leading foodservice and support services company in North America. We pride ourselves on our ability to provide clients with a wide range of innovative dining and support service solutions. We have a passion for great food and great service. We create inspiring dining solutions that deliver the full benefit of outsourced food services, combining our nationwide strength with passionate local teams. We operate at thousands of client locations around the country, from hospitals, schools, and oil rigs to corporate headquarters and the nation’s biggest entertainment venues. We also supply food and ingredients to some of the most visible, renowned, and successful food service venues in the country. We can also support our clients beyond food with a range of other support services – consistently delivered to a high standard, cost effectively. PP - What personal information do we collect and why? What personal information do we collect and why? Our family of companies provides customers with a diverse set of goods and services, and as a result, collects various kinds of data related to those goods and services. The following are examples of the kinds of data we may collect from you: 1. Personal Information that can be used to identify you, including your name, address, telephone number, email address, where you go to school or work, and other similar identifiers 2. Business and transactional information, including purchase histories, and search histories. 3. Payment and payment card information, including payment card numbers, account information, and bank information. 4. Biometric data, including fingerprints or images 5. Browsing information, including internet browsing history, search histories, browser identification, and IP address. 6. Geolocation data, used to identify your location for use of our location-specific services. 7. Demographic information, including age, race, gender, medical conditions, allergies, and familial status. My Health My Data Non-HIPAA Health Data (My Health My Data) We do not, generally, collect your "consumer health data" as part of our normal operations. However, under certain state laws related to foodborne illnesses, we may reach out to you for more information in the event you notify us of a problem in our goods or services. You may, at your option and with your explicit consent, include certain health data when answering questions about your incident such as information about your symptoms and/or documentation from a doctor. This information is not collected or used for any purpose other than to comply with relevant food safety and state health department laws and regulations. We do not sell this data. We do not share it with third parties other than these relevant government entities, and then only upon their request. We keep this information only for a period no longer than applicable retention requirements, after which it is deleted. You may withdraw your consent, or ask that this information be deleted or anonymized, by emailing us at privacy@compass-usa.com (mailto:privacy@compass-usa.com). PP - Where do we get the information? Where do we get the information? The data we collect can come from a diverse array of sources, including: 1. You directly 2. Our client, customers, and business partners that serve you 3. Advertising networks 4. Internet service providers 5. Data analytics providers 6. Government entities 7. Operating systems and platforms 8. Social networks and other social media platforms 9. Data brokers PP - How we use your information How we use your Information. Because we provide such a broad range of services to diverse groups of consumers like you, our use of your information will vary. However, the following are ways that we, our member companies, and our business partners may use your data: 1. To complete transactions, ship your goods, serve your food or otherwise provide the goods and services you’ve ordered from us. 2. To provide you with customer service support and to communicate with you regarding our goods and services 3. To personalize the contents of the sites you use, and deliver custom product and service offerings based on your interests 4. Protect the privacy and security of your data, and our systems, including fraud and malware detection 5. To fulfill our obligations under the law 6. To maintain the quality and safety of our computer systems, products, and other services 7. For internal research and technological development purposes 8. For any other purpose that you consent to in your interactions with us. PP - Who do we share data with? Who do we share data with? We don’t sell your data, and in most cases the data we do share with others is anonymous, aggregate data that allows us to track and improve our services overall, and to enable our business partners to better serve customers like you. However, we do share your data with certain third parties, including our family of affiliated companies to provide you with the goods and services we offer: 1. To shipping companies, payment card processors, and other third parties necessary to process your orders with us and deliver the goods or services to you. 2. To process any request you provide to us, such as through our customer service teams or other online portal 3. To enforce or apply our Terms of Use, Terms and Conditions, or other agreements, including for billing and collection purposes. 4. When we operate this site on behalf a business as a service provider, we will share that information with the that business. Any such businesses will be described in the introduction to this policy. 5. To business partners that help us (a) manage and provide services related to our websites, mobile applications, communications with you; (b) communicate with you about our products, services and offerings; and (c) to improve your experience when interacting with us. 6. To comply with the law or court order, or to protect the rights, property, or safety of you, our customers, our employees, or others. PP or TOU - Security Security We use appropriate technical, administrative and physical safeguards to protect the personal information that we collect about you, based on the information collected. Some of our services require you to create a user account. Please utilize a strong, complex password in connection with these accounts. Keep this password secret and secure. We are not responsible for any orders placed, or any misuse of your account that occurs as the result of a lost device, weak password, malware or other similar issue. Please note that some of our sites contain links to third party websites. We are not responsible for the contents of these sites, their privacy practices, or compliance with the law. Please note the privacy policy of any site linked to from one of our websites for additional information. PP - Minors Minors With limited, noted exceptions, our sites are not meant to be used by minors. We do not knowingly collect or process the information of children under the age of 13, and no one under that age should enter any information into any of our sites without providing prior parental consent. If you are under the age of 13, do not use our sites or provide any information through them. If we determine or are notified that information about a minor under the age of 13 has been provided through our sites, we will delete it immediately. PP - Updates Updates We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we do update it, we will take appropriate measures to notify you, commensurate with the significance of the changes we make. When we change this Privacy Notice, the date at the bottom of the policy will be updated to reflect the effective date of the policy. PP- Contact Us Contact Us If you have any questions or concerns about the Privacy Policy, please email us at PrivacyTeam@Compass-USA.com; send us physical mail at 2400 Yorkmont Road, Charlotte, NC 28217; or call us at (833) 935-1141. PP - Your Rights Your Rights At any time you may exercise any one of the following rights to your data by calling us at (833) 935-1141 or contacting us via this link. (https://privacyportal-eu.onetrust.com/webform/8394ad8c-2b46-4837-8771-cbc69779a644/31bea1f4-92c3-440b-be0e-468af4f4b1f3) 1. Right to Know You have the right to ask us about whether we have collected and/or process your data, what categories of data have been collected about you, the reasons for the collection of that data, and what we do with that data. You have the right to make a general request related to our overall practices, and you have the right to request a copy of the specific information we have collected about you. Please note certain particularly sensitive data cannot be shared, including social security numbers, financial card data, and other similar information. 2. Right to Delete In certain states, you have the right to request that we delete the information we have about you. Please note that not all data can always be deleted. We will not delete data that we are required to retain to comply with certain laws, for example. Also, please be aware that completing your request may mean we can no longer provide certain services to you that rely on that data, including product returns, refunds, and other customer service functions. 3. Right to Correct You have the right to contact us and ask that the information we have about you be corrected. 4. Right to Opt Out You have the right to opt out of the sale or sharing of your personal information. At this time, Compass does not sell or share your personal information. As a result, we do not honor Opt-Out requests. Similarly, we do not honor "opt-out preference signals." NOTE: At this time we do not sell or share your data. 5. Right to Limit the Use and Disclosure of your Sensitive Personal Information You may request that we limit the use and disclosure of any sensitive personal information we have collected about you. Please be aware that, in general, Compass does not collect Sensitive personal information. In the event that we do, we only use and disclose that information (a) in direct relation to the goods and services we are providing to you; or (b) as required by applicable law. When you make one of these requests, we require you to submit sufficient information to both verify your identity and search our systems for information related to you. Please note, that certain requests require additional information to verify your identity. We do this to protect the security and privacy of your data, the security of your accounts with us, and to comply with the law. You may also use an authorized agent to make one of these requests, but please be aware that additional requirements do apply. Your agent must either provide an executed power of attorney compliant with laws in your state, or provide a document evidencing that they are your agent, after which we will contact you to verify that the agent is working on your behalf. We do not collect household data, and as a result do not honor household requests. We do not use your data for any kind of automated decision making process, and so cannot process requests related to such activities. If you have any questions about how to submit a request, please email privacy@compass-usa.com (mailto:privacy@compass-usa.com). We also provide you with the ability to appeal any decision to reject a request you make to us related to your Personal Information. Once you have submitted a request, as described above, and receive a decision you do not agree with, you may submit an appeal by filling out the form HERE (https://privacyportal-eu.onetrust.com/webform/8394ad8c-2b46-4837-8771-cbc69779a644/745c5942-1c7b-4776-a47d-d25601e8939d). Non-Discrimination We do not discriminate against consumers that file requests under this policy. You will continue to receive the same services you are used to, with the exception of those that cannot be completed due to the request. For example, if we delete your purchase history or personal identifiers, we may not be able to provide product returns or warranty support. Appeals If you submit a request using the methods described above, and you disagree with the outcome, you may submit an appeal by completing the form HERE (https://privacyportal-eu.onetrust.com/webform/8394ad8c-2b46-4837-8771-cbc69779a644/745c5942-1c7b-4776-a47d-d25601e8939d).