PRIVACY POLICY

Effective Date: January 1, 2020

This Privacy Statement (“statement”) applies to Kent Nutrition Group, Inc. and its commonly controlled
affiliate entities’ (“KNG”) handling, use, and disclosure of your personal information. KNG is committed
to maintaining the privacy of the personal information it collects and maintains.

The Types of Information and Data We Collect and the Legal Basis

We may collect your personal information when you interact with us. Our collection of personal information is not limited to your interaction with our website. Below is more detailed information about how we collect personal information.

Information that you provide to us

You may be requested to voluntarily provide your personal information when interacting with our website, such as when you are subscribing to marketing updates or requesting product information. We may also collect personal information from you at tradeshows or similar events, when you register as a visitor at our offices, or when we communicate for the purpose of beginning or continuing a business relationship.

The personal information we collect may include:

  • Contact information which is information that assists us in identifying you and communicating with you, such as your name, phone number, address, email address, and mailing address;
  • Business completion information, which is information that assists us in furthering or completing our services, such as information about your purchase and/or inquiry, customer
    account information, company name, job title, work address, and payment instructions; and
  • General information, which is information that helps us understand who you are and what you may want, such as your location, business information, and demographic information.

Information that we may collect automatically

Like most websites, we collect personal information about our website visitors using automated methods. The information we collect assists us in understanding how our website is being used. When you visit our websites we may collect the following information about you:

  • Information related to your visit, such as how long you remained on our websites, how you found or accessed our websites, your geographic information when you visit our websites
  • Information about the device you used to access our websites, such as your IP address, operating system, device, and browser type.

In order to collect this information we may use cookies and/or flash cookies (each a small file placed on your computer’s hard drive that assists our technology resources in identifying your future visits to our website), pixel tags/web beacons (a small image that allows us to determine if you have viewed specific content on a webpage or in a communication), embedded weblinks, and similar technologies. We may use vendors or tools available from third parties to collect this information. Most web browsers provide a default setting that opt in to sharing information with us. If you would like to change this setting you should review your browser’s features to determine how you can change them. However, changing the way your browser interacts with our website may change the functionality or features of our website when you visit.

Information we may collect from third parties

We may collect information about you from third parties, such as public databases, professional websites, social media platforms, joint marketing partners, or data providers. This information may include your name, email address, professional information, professional background, location/address, IP addresses, phone number, and/or address.

In combination with other personal information we have collected, we may use this information to further market our products and provide our services to you, including providing targeted advertising and customized communications. We may also use this information to protect our legal interests, including our digital and physical assets.

How We Use Your Information

We use the personal information that we collect for the below purposes (alone or in combination with other pieces of personal information).

  • For marketing and advertising purposes, such as:
  1. Communicating with you for marketing and promotional purposes, including sending
    you newsletters, emails, SMS text notifications, and direct mailings;
  2. Understanding how our website is used and how visitors interact with it to assist in our
    understanding if the information provided is effectively presented;
  3. Providing personalized advertising to you both on our website and on other websites you may visit, based on your browsing activities, and advertise our services and products and/or with your consent;
  4. Understanding and analyzing how you use our website and services, and develop new
    features and services to increase the functionality of this website;
  5. Developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
  • For security purposes, such as
  1. Maintaining your safety and the safety of our personnel if you are on-site and to
    manage access
  2. Managing access to confidential information that we possesses to the extent necessary for maintaining safety and security and comply with our legal agreements;
  3. Safeguarding our assets, including our websites; and
  4. Detecting, preventing, or otherwise addressing fraud, security, or technical issues.
  • For fulfillment purposes, such as
  1. Sending product, order, or account information to you;
  2. To respond to your requests or provide information you have requested;
  3. Communicating with you, including providing you with updates of the services we
    provide, provide the information you request, respond to your questions, comments, and suggestions, and continue providing customer support;
  • For technical purposes, such as:
  1. Monitoring our website usage and data, identifying trends, determining the
    effectiveness of our marketing efforts, and enhancing the functionality of our websites to assist us in expanding and developing our business activities;
  2. Administering, troubleshooting, testing, conducting data analysis, and reviewing the features of our websites.
  • To comply with our legal requirements, including complying with applicable laws, agreements, and policies;
  • For any other purpose we describe to you before receiving your content.

How We Share the Information

Vendors, consultants, agents, and other service providers

We may share your information with these persons to assist us with enhancing our business processes, our services, and/or our products. These services include our data processing, billing, customer support, information technology infrastructure, hosting our information technology infrastructure, providing security services (physical and electronic), or optimizing our online or offline marketing efforts.

Professional advisors

We may share your information with our professional advisors, including lawyers, bankers, auditors, insurers, where it is necessary for them to provide us their professional services.

Compliance with laws

We may share your information with any regulatory, governmental body, competent court of law, or in response to any proper legal demand, such as a court order or subpoena. We will only disclose your information where we believe it is required by law.

Other instances when we may share information

We may share your information when we believe it is necessary to protect the vital interests or legal rights of KNG, you, or any other person.

We may share your information with our commonly owned affiliated entities, who are also limited to using your personal information as detailed in this statement. Your information may also be disclosed in the event of a merger or sale of all or a portion of our assets.
We may disclose aggregated information about our website visitors, and information that does not identify any individual, without restriction.

Your Choices About How We May Disclose Your Information

We strive to provide you with choices about how we collect and maintain your personal information. In certain instances we provide your choices related our collection or handling of your information, such as:

  • Opting out by checking the relevant box located on the form on which we collect your data; or
  • Contacting us to have us remove you from our promotional communications.

Your Rights

Where required by law, we provide the ability for you to access, modify, change, update, or delete personal information related to you that we have collected or maintain. You may contact us to exercise these rights by emailing privacy@kentnutritiongroup.com. We may not be able to accommodate your request if we believe the change would violate any applicable law or legal requirement or we have other just cause to decline your request. We will notify you of our rationale if that is the case.

Data Security

We have implemented procedural, technical, and physical safeguards to prevent the unauthorized access to or deletion of your personal information that we have collected or maintain.

The safety of your information also depends on your practices. Where we have provided you a password to access features, you should not make that password available to third parties. You should also consider that the internet is not completely secure. While we do our best to protect your personal information that we have collected or maintain, any time you transmit this information it is susceptible to being intercepted.

Third Party Practices Beyond Our Control

This policy does not address how your personal information is collected or utilized if you leave our website for another website, even if through a link that we provide, or if you interact with a third party plug-in embedded in our website (such as a social media feed). We do not control these third parties.

You should review the privacy practices for those websites to learn more about your rights related to how they may handle your information.

Information collected by third parties, either through the use of any application or content (including advertising) or through access to their website through links that we provide.

You may also be able to opt out of receiving targeted ads or other third party tracking by opting out on the Network Advertising Initiative’s website.

Children’s Privacy

Our services are not intended to be used by children under the age of 16 and we do not knowingly collect, maintain, or use personal information from them. If you learn that a child has provided personal information to us in violation of this Privacy Policy, you may alert us at
privacy@kentnutritiongroup.com.

Jurisdiction

Our services are hosted in the United States and our website is intended solely for traffic from the United States. If you choose to use this website outside of the United States you should be aware that you are transferring your personal information outside of the region where you are located for storage and processing. By providing any information, you are consenting to the transfer, storage, and processing of your personal information outside of the region where you are located.

Updates to this Privacy Policy

We reserve the right to update this Privacy Policy at our discretion at any time. Updates will be posted on this page and are effective upon posting. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have questions, comments, or concerns about this policy please submit them to
privacy@kentnutritiongroup.com.

CALIFORNIA PRIVACY NOTICE

EFFECTIVE DATE: January 1, 2020

The information in this California Privacy Notice (“Notice”) supplements the information contained in our Privacy Statement and applies only to California residents. The terms used within this Notice have the same meaning as defined within the California Consumer Privacy Act of 2018, as amended.

Information We Collect

Our websites collect information that alone, or in combination with other information, identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Kent Nutrition Group, Inc. (“KNG”, “we”, “our”, “us”) collects the below categories of personal information, which collection has not changed within the prior 12 months.

  • Identifiers, such as your real name, mailing address or email address;
  • Personal Information, such as your, signature, Social Security Number or bank account number;
  • Protected Classification Characteristics, such as your age or gender;
  • Commercial Information, such as records of your purchasing tendencies or purchase history;
  • Internet or other similar network activity, such as browsing history, search history, information on your interaction with our website;
  • Geolocation data, such as your physical location or movements;
  • Professional or employment-related information, such as your current or past employment information and performance evaluations;
  • Non-public education information, such as your transcripts or grades; and
  • Inferences drawn from other personal information, such as your abilities, aptitudes, and predispositions.

Depending on your relationship to us (consumer, customer, employee, service provider), we obtain this information either directly from you or from your interactions with us.

How We Use Personal Information

We use the personal information that we collect for the below purposes (alone or in combination with other pieces of personal information).

  • For marketing and advertising purposes, such as:
  1. Communicating with you for marketing and promotional purposes, including sending
    you newsletters, emails, SMS text notifications, and direct mailings;
  2. Understanding how our website is used and how visitors interact with it to assist in our understanding if the information provided is effectively presented;
  3. Providing personalized advertising to you both on our website and on other websites you may visit, based on your browsing activities, and advertise our services and products and/or with your consent;
  4. Understanding and analyzing how you use our website and services, and develop new
    features and services to increase the functionality of this website;
  5. Developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
  • For security purposes, such as
  1. Maintaining your safety and the safety of our personnel if you are on-site and to
    manage access
  2. Managing access to confidential information that we possesses to the extent necessary maintaining safety and security and comply with our legal agreements;
  3. Safeguarding our assets, including our websites; and
  4. Detecting, preventing, or otherwise addressing fraud, security, or technical issues.
  • For fulfillment purposes, such as
  1. Sending product, order, or account information to you;
  2. To respond to your requests or provide information you have requested;
  3. Communicating with you, including providing you with updates of the services we
    provide, provide the information you request, respond to your questions, comments, and suggestions, and continue providing customer support;
  • For technical purposes, such as:
  1. Monitoring our website usage and data, identifying trends, determining the
    effectiveness of our marketing efforts, and enhancing the functionality of our websites to assist us in expanding and developing our business activities;
  2. Administering, troubleshooting, testing, conducting data analysis, and reviewing the
    features of our websites.
  • To comply with our legal requirements, including complying with applicable laws, agreements, and policies;
  • For any other purpose we describe to you before receiving your content.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

How We Share the Information

We may share your personal information with third parties for a business purpose or transfer your personal information subject to your right to opt-out of those sales. If we disclose personal information to a third party for a business purpose we require that third party to maintain the confidentiality of your personal information and prohibit them from using it for any other purposes.

Within the last 12 months we have sold the below categories of personal information to service providers and data aggregators (who aggregate and de-identify information) for a business purpose.

Category of Personal Information collected from Business Partners, Visitors, Customers, and Consumers
Where We Collect This Information From and Who We May Share It With
 How We Use The Information
Identifiers collected from Business Partners, Visitors, Customers, and Consumers
Collected from: Social media, you, data brokers, service providers, business partners
Shared with: same as above except data brokers
Understanding our product markets and enhancing our brands, ensuring the security of our websites and physical locations, engaging in a business-to-business context with third parties through the distribution of our products/ services
California customer records
collected from Business
Partners, Visitors, Customers,
and Consumers
Collected from: service
providers, business partners,
data brokers
Shared with: same as above
except data brokers
Understanding our product
markets and enhancing our
brands, ensuring the security of
our websites and physical
locations, engaging in a
business-to-business context
with third parties through the
distribution of our
products/services
Protected classification
characteristics collected from
Business Partners, Visitors,
Customers, and Consumers
Collected from: social media,
you, a party you have
authorized to provide this
information to us, business partners, service providers
Shared with: same as above
Understanding our product
markets and enhancing our
brands, employment searches,
engaging in a business-to-business context with third
parties through the distribution
of our products/services
Commercial information
collected from Business
Partners, Visitors, Customers,
and Consumers
Collected from: our records,
business partners, service
providers, you, a party you have
authorized to provide this
information to us
Shared with: same as above
Understanding our product
markets and enhancing our
brands, engaging in a business-
to-business context with third
parties through the distribution
of our products/services
Internet or other similar
network activity collected from
Business Partners, Visitors,
Customers, and Consumers
Collected from: service
providers, business partners,
data brokers
Shared with: same as above
except data brokers
Understanding our product
markets and enhancing our
brands, engaging in a business-
to-business context with third
parties through the distribution
of our products/services
Geolocation data collected from
Business Partners, Visitors,
Customers, and Consumers
Collected from: service
providers, business partners,
data brokers
Shared with: same as above
except data brokers
Understanding our product
markets and enhancing our
brands, engaging in a business-
to-business context with third
parties through the distribution
of our products/services
Professional or employment-
related information collected
from Business Partners, Visitors,
Customers, and Consumers
Collected from: social media,
you, a party you have
authorized to provide this
information to us
Shared with: same as above
except data brokers
Understanding our product
markets and enhancing our
brands, employment searches,
engaging in a business-to-
business context with third
parties through the distribution
of our products/services
Non-public education
information collected from
Employees and Potential
Employees
Collected from: you, a party you
have authorized to provide this
information to us, service
providers, business partners
Shared with: same as above
Conducting employment
searches and fulfilling
Inferences drawn from other
personal information collected
from Business Partners, Visitors,
Customers, and Consumers
Collected from: service
providers, business partners
Understanding our product
markets and enhancing our
brands

We have not sold the below categories of personal information to a service provider for a business
purpose within the last 12 months.

  • Biometric information
  • Sensory data

Your Rights and Choices

You are provided specific rights under the CCPA. This section of this Policy describes how you may exercise those rights.

Access and Portability

You have the right to request that we disclose information to you about our collection and use of your personal information. If you submit an access or portability request we will verify your request and respond promptly and as required by the CCPA.

We will provide you: the categories of personal information we collected about you; the categories of sources for the personal information we collected about you; our business or commercial purpose for collecting or selling that personal information; the categories of third parties with whom we share that personal information; the specific pieces of personal information we collected about you (also called a data portability request); whether we sold or disclosed your personal information for a business purpose, two separate lists disclosing; sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion

You have the right to request that we delete the personal information that we have collected or maintain related to you upon receiving a verified request. However, these requests are subject to restrictions.

We may deny your request if retaining your personal information is necessary for us or our service provider to: complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; enable solely internal uses that a reasonably aligned with consumer expectations based on your relationship with us; comply with a legal obligation; make other internal and lawful uses of that information that are compatible with the context in which you provided it; or any other reason permitted by law, which we will inform you of in our response.

Sales Opt-Outs and Opt-Ins

If you are 16 or older, you may direct us not to sell your personal information. Please click this link if you would like to opt out: Do Not Sell My Personal Information. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with your request. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by: Do Not Sell My Personal Information.

Exercising Your Rights and Contacting Us

Making a Request

To exercise your access, portability, and deletion rights please submit a request to us using our online form or by calling us at 1-833-981-0968. You may also authorize another person to act on your behalf to

make these requests. Your request should provide sufficient information to allow us to properly respond. If we are not able to verify your request we will not be able to fully respond to your inquiry and may be required to reject it.

You may also write to us with these requests or any other concerns with this policy. Please address your correspondence to:

Legal Department
Privacy Practices
2905 US Hwy 61N
Muscatine, IA 52761

Our Response

We endeavor to respond to your request promptly but no later than 45 days after receiving it and will inform you if more time is necessary to respond.

Children’s Privacy

Our services are not intended to be used by children under the age of 16 and we do not knowingly sell, collect, maintain, or use personal information from them. If you learn that a child has provided personal information to us in violation of this Privacy Policy, you may alert us at privacy@kentnutritiongroup.com.

Non-Discrimination

We do not discriminate against anyone for exercising their rights under CCPA. That means that unless we are allowed by law, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality level, which will reasonably relate to your personal information’s value and contain written terms that
describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@kentnutritiongroup.com or write us at: Privacy Practices, Attn: Legal Department, 2905 US Highway 61N, Muscatine, IA 52761.

Updates to this Privacy Policy

We reserve the right to update this Privacy Policy at our discretion at any time. Updates will be posted on this page and are effective upon posting. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.