FSD takes your privacy seriously. The following principles guide our treatment of your personal information:

1. We value the trust you place in FSD when sharing your personal information with us.
2. We strive to be transparent with you about what personal information we collect, what we do with it and with whom we share it.
3. We endeavor to work with you to address your concerns about how we use your personal information.
4. We strive to take steps designed to secure your personal information and reduce the risk it will be misused.

This Privacy Policy (“Policy”) describes how FoodServiceDirect (“FSD,” “we,” “us,” or “our”) collects, uses, shares and otherwise processes personal information in connection with our websites where the Policy is located, including the mobile versions of our websites (the “Platform”). This Policy is not, however, a contract and does not create any legal rights or obligations.

When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

FSD collects information from you and about you. Here are some examples of the information we may collect:

Contact Information. For example, we may collect your name, mailing address,phone number, mobile number and email address.

Payment Information. For example, we may collect your credit card number and billing address.

Shopping History. For example, we may collect personal information about the items you viewed, added to your cart or purchased.

Information You Post. We may collect personal information you post in a public space on our Platform, such as testimonials and reviews.

Social Media Information. We may collect personal information you post on our social media pages. We may also collect your social media profile information and personal information posted on your page.

Employment Information. If you apply for a job through our Platform, we collect the personal information you include in your application. For example, this may include the name and address of your employer and your employment history.

Information You Submit. We may collect personal information when you send us a message through the email address on the Platform or the livechat feature on the Platform. We may also collect personal information when you enter a promotion. This may include photos, videos, and other user-generated content that you submit.

Demographic Information. We may collect your birthdate, age, gender, and zip code. We may also collect personal information relating to your hobbies, interests, and shopping behavior.

Device Information. We may collect the type of device you use to access our Platform. We may also collect your device identifier, IP address, or mobile operating system.

Location Information. We may collect precise location information from your device. This may include information about your exact location when you use our Platform or may include information that allows us to approximate your location. We may also collect this information in the background when our mobile applications are not in use. For more information about your options related to the collection of your location information, see the Choices Regarding Your Personal Information section below.

Log and Analytics Data If you use our website, we may collect information about the browser you are using. We may look at what site you came from or what site you visit when you leave us. If you use our app, we may look at how often you use the app and where you downloaded it.

We collect your personal information in the following ways:

Directly From You. For example, when you:

• Register for an account.
• Purchase products or services through our Platform.
• Sign up to receive promotional communications (email and SMS/MMS).
• Join a loyalty, rewards, or similar program or club.
• Participate in one of our promotional sweepstakes, contests, surveys, or focus groups.
• Use the Testimonials feature or related services and features.
• Submit a request to our Consumer Service team.
• Interact with our brand ambassadors.
• Interact with FSD social media pages.
• Apply for a job through our Platform.

Automatically. For example, when you:

• Install and use FSD mobile apps.
• Visit and navigate our Platform on any device.
• Enable location-based features on our Platform.
• Click on sponsored links or third-party advertisements.

We may also collect personal information about you over time and across different websites, apps, and devices when you use our Platform, using tracking technologies such as cookies, pixels, Flash objects, APIs, and mobile software development kits (SDKs). We may use third-party services to collect this personal information when you use our Platform. For more information about our use of cookies and other tracking technologies to collect personal information about you automatically, see the Online Advertising and Third-Party Tracking section below.

From Third Parties. We may receive personal information about you from other sources. For example, this may include receiving personal information from:

• Our business partners, including online advertising networks, analytics vendors, and companies that co-sponsor our promotions.
• Social media sites, including Facebook, Twitter, YouTube, Pinterest, Snapchat, TikTok, and Instagram. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site.
• Third-party sites, including those that allow you to integrate your third-party account with your FSD account.
• Family, friends, and others who provide your personal information to us because they think you may be interested in our products and services or they want to share a product or service with you (including our referral programs).
• Companies that provide personal information to supplement what we already know about you, including data aggregators. Certain third parties might link your name or email address to other information they have collected. That might include past purchases made offline or online. It might also include online usage information.

By Combining Personal Information. For example, we may:

• Combine personal information that we collect offline with personal information we collect through our Platform.
• Combine personal information we collect about you from the different devices you use to access our Platform.
• Combine personal information we get from third parties with personal information we already have about you.

We may use your personal information in the following ways:

To Provide Our Products and Services: Fulfill requests, process transactions, manage shopping list.
To Improve Our Products and Services: Enhance Platform, customize experience.
To Understand Your Interests: Better grasp product interests.
To Respond to Your Requests or Questions: Address feedback, notify promotion wins.
To Communicate With You: Manage account, discuss relationship, inform about Policy or Terms of Use.
To Determine Your Eligibility: Verify identity, assess eligibility for products, services, promotions, or job applications.
For Marketing Purposes: Provide info on products, special offers, serve ads, share updates through electronic communications.
For Interest-Based Advertising: Engage in interest-based advertising across platforms.
For Security Purposes: Protect company, consumers, and Platform.
To Send Push Notifications: Notify about new products, special offers through mobile apps.
As Otherwise Permitted By Law or As We May Notify You.

We may share your personal information in the following ways:

Internally: We may share your personal information within Conopco Inc.
On our Platform: For example, we may display personal information you post on our Testimonials feature. We may also display personal information you submit in connection with a promotion.
With Our Service Providers: We may share your personal information with third parties who perform services on our behalf. For example, this may include payment processors and companies that send emails on our behalf or help us run our Platform.
With Our Business Partners: For example, this may include a third party that co-sponsors a contest or promotion. We may also share personal information with data aggregators, advertisers, media buying agencies, advertising networks and advertising service providers.
With Third Parties for Marketing Purposes: This may include our affiliate companies or brands or third parties whose products or services we believe you may be interested. These third parties may also share your personal information with others. These third parties may use your personal information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.
For Business Transactions or Reorganizations: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of our company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
To Comply With the Law or To Protect Ourselves or Third Parties: For example, this could include responding to a court order or subpoena. It could also include sharing personal information if a government agency or investigatory body requests. We might share personal information when we are investigating potential fraud. This could include fraud we think has occurred during a sweepstakes or promotion. We may also share information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
For Other Reasons We May Describe to You.

Our Platform does not sell products for purchase by children. Our Platform is intended for adults who are primarily purchasing for a business. We do not knowingly collect or solicit any information from anyone under the age of 14 through our Platform. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you are a parent or legal guardian and believe your child under 14 has provided us with personal information, please contact us at privacy@foodservicedirect.com.

Marketing Communications:
You can opt out of receiving our marketing communications. Note that you will still receive non-marketing or transactional messages from us, including messages about your account, orders, and responses to your inquiries. To opt out of receiving our marketing communications, you can contact us as follows:

• Send us an email at privacy@foodservicedirect.com.
• Call us at 855-705-0755 (Monday through Friday, 9:00 AM 5:00 PM Eastern).
• Send us a letter at:
  Food Service Direct Logistics Canada, Inc.
  1259 Centennial Dr.
  Unit 3
  Kingston, Ontario K7P0C3
• For promotional emails or text messages, follow the instructions included with the marketing communication.

Mobile Application and Location Based Services:
You may control our collection and use of location-based information through our mobile applications by adjusting the settings on your mobile device. If you withdraw permission for mobile applications to access precise location data, we may continue to approximate your location based on information like your IP address. You may completely opt out of all location-based information collection by our mobile applications if you uninstall all of our mobile apps from your devices.

Cookies & Other Tracking Technologies:
We automatically collect certain types of usage and device information when you visit our Platform, read our emails or otherwise engage with us. We typically collect this information through the use of cookies (a small text file sent from a website and stored on your device), web beacons or pixels and similar tracking technologies, and we may utilize third party services to collect this information. For example, these tracking technologies may collect information about your device and its software, such as your IP address, browser type, device type, date and time stamp, unique device ID, and about the way you engage with our Platform, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, how frequently you access our Platform, whether you open emails or click the links contained in emails, whether you access the Platform from multiple devices, the products you view and click on, and similar actions you take.

We use this information collected through tracking technologies to provide custom, personalized content and information, including targeted content and advertising, recognize you across multiple devices, monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, and otherwise enhance our Platform and your user experience.

Your browser may give you the ability to control cookies or other tracking technologies, or to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.

If you block cookies, certain features on our Platform may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques. In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use.

Interest-Based Advertising:
We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests. We permit third party online advertising networks, social media companies, and other third party services to collect information about your use of our websites and Platform over time so that they may play or display ads on our Platform, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices or serve you ads on social media sites you may use. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit https://youradchoices.ca/. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our advertising partners, please follow the instructions at https://youradchoices.ca/en/tools to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.

If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at https://youradchoices.ca/en/tools.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us on our website or third-party websites. It means that the online ads that you do see from DAA and NAI program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties' opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention and similar purposes.

Google Analytics and Advertising:
We use Google Analytics to better understand how our users interact with our Platform. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses information from sites or apps that use our services” located at www.google.com/policies/privacy/partners/.

You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On at www.tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at www.google.com/ads/preferences or by vising NAI’s online resources at www.networkadvertising.org/choices.

Our Do Not Track Policy:
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block or reject cookies, not all of the tracking described here will stop. Options you select are browser and device specific.

ACCESSING OR CORRECTING YOUR INFORMATION:
You have the right, under certain circumstances, to access and correct information we hold about you. Any such access request must be in writing and provided to us at the email or postal address provided in the Contact Us section below. Any such access request may be subject to a small statutory fee to meet our costs in providing you with details of of the information we hold about you, where permitted by applicable law.

OUR PRIVACY OFFICER AND PRIVACY COMPLIANCE FRAMEWORK

FSD has appointed a Privacy Officer who is responsible for overseeing our compliance with this Privacy Policy and our practices relating to privacy of personal information. See Contact Us for information on how to contact the Privacy Officer.

We maintain a framework for the protection of any personal information that we collect. The framework includes policies and procedures designed to help us comply with this Privacy Policy. This framework requires all employees to protect the confidentiality of any personal information that we handle through the lifecycle of that personal information. The privacy framework includes employee codes of conduct, breach reporting obligations, data retention and destruction policies, employee training, and procedures for addressing complaints and providing individuals with access to their personal information in accordance with this Privacy Policy.

PROVINCE-SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please refer below for disclosures that may be applicable to you.

If you are a resident of Quebec and we collect personal information about you in Quebec, that information will be communicated outside of Quebec to other locations in Canada, the United States and other places where we or our service providers process your information.

Collection of Mobile Phone Numbers: We collect mobile phone numbers when you opt-in to our SMS/MMS marketing services. This may occur when you provide your mobile phone number on our website, during account registration, or as part of purchasing processes.

Use of Personal Information for SMS/MMS Marketing: When you opt into our SMS/MMS marketing services, we use your mobile number to send you promotional messages about our products, services, and special offers. The frequency of these messages will vary but will be clearly communicated during the opt-in process.

Opt-In Consent: By providing your mobile number and opting into our SMS/MMS marketing services, you give us explicit consent to send you text messages. We will provide a clear and concise method for you to give this consent.

Opt-Out and Withdrawal of Consent: You can opt out of our SMS/MMS marketing services at any time. Instructions for opting out will be included in every marketing SMS/MMS we send. Upon opting out, you will no longer receive marketing texts from us, but you may still receive transactional messages (e.g., order confirmations).

Data Security for Mobile Numbers: We employ security measures to protect your mobile phone number from unauthorized access and use. Your number is only used for SMS/MMS marketing purposes as you've consented.

Third-Party Service Providers: We may use third-party service providers to facilitate our SMS/MMS marketing. We ensure these providers adhere to strict data protection and privacy standards.

Changes to SMS/MMS Marketing Practices: If we make changes to our SMS/MMS marketing practices, we will update this policy accordingly. You will be notified of any significant changes as per our standard policy update procedures.

The Internet is not 100% secure. Like all businesses, we cannot guarantee the security of the personal information you provide to us via the Platform. We have, however, taken certain steps designed to reduce the risk that the personal information you provide us will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction. We encourage you to use caution when using the Internet. A user ID and a password are needed to access certain areas of the FSD Platform. It is your responsibility to protect your username and password.

Personal information we maintain may be stored in or outside of Canada. If you live outside of Canada, you understand and agree that we may transfer your personal information to Canada. This Platform is intended for use in Canada and is subject to the laws of Canada, which may not provide the same level of protection as those in your own country.

Our Platform may contain links to other third-party sites, plug-ins, applications or other online services. If you click on a link to a third-party site or other online service, you will be taken to a site or other online service we do not control and that is not governed by this Policy. We are not responsible for the privacy practices used by third-party sites and other online services. We suggest that you read the privacy policies of those sites and other online services carefully.

If you have any questions, comments, or concerns regarding our privacy practices or this Policy, or if you wish to update your information, please feel free to contact us:

• Email: privacy@foodservicedirect.com
• Telephone: 855-705-0755 (Monday through Friday, 9:00 AM – 5:00 PM Eastern)
• Mail:

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy of this Policy on our Platform. Please check our Platform periodically for updates.