Privacy Policy | Manna Pro

DATA PRIVACY NOTICE OVERVIEW

Scope

This Data Privacy Notice applies to all customers, contacts, vendors, agents, and job applicants of Compana Pet Brands LLC and all of our brands (“Compana”, “we/our/us”), and all visitors to our websites, except as specified herein. For a complete list of Compana’s brands, please click here: https://companapetbrands.com/our-brands.

Personal Information

We receive personal information directly from you and in our transactions and trusted interactions with you. We may also automatically collect personal information from you on our websites. For more information about our use of cookies, please visit our Cookie Policy. We also occasionally receive personal information about you from commercial sources.

Uses

We primarily use your personal information to provide (and facilitate the provision of) our traditional animal health and nutrition products and services to our customers, and respond to your inquiries regarding the same. We also use your personal information to market to you, to communicate with you, to manage business operations, and to comply with our legal obligations.

We explicitly do not “sell” (as this term is traditionally defined) your personal information to outside parties, including, but not limited to, marketers. We do, however, provide your personal information to our data management providers to facilitate our legitimate business purposes.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information only for business record auditing, statutory record retention, defense or maintenance of a legal claim, or complaint resolution and handling purposes. We will delete your personal information, or aggregate or de-identify your personal information so that it is no longer personally identifiable, when it is no longer required for these purposes.

Nonetheless, you have the right to review and correct your personal information that we have received from you. You also have the right to request that personal information collected be erased before the end of our usual information retention periods. You may also have the right to limit certain uses or disclosures of your information.

Information Security

We are also concerned with the security of your personal information and take great care in implementing appropriate physical, technical, and administrative controls to protect your personal information. Unfortunately, no information transmission or maintenance and processing of personal information can be guaranteed to be 100% secure.

Choices

We only market other products and services to you with your consent, based on your marketing preferences. You may create or change your privacy preferences in connection with our marketing efforts by contacting our Privacy Manager at privacy@companapetbrands.com.

You also may amend your cookie preferences for any of our animal health and nutrition websites through your browser settings. However, in addition to marketing and analytics features, we also use cookies to enable and improve certain functions of our websites. If you choose to switch off or disable certain essential cookies, it is likely to affect how that particular website works on your computer, smartphone, or device.

EU Residents

Our EU subsidiary, Manna Pro UK, Ltd. has taken appropriate measures to comply with the European Union (“EU’s”) General Data Protection Regulation (“GDPR”). Manna Pro UK’s GDPR Privacy Statement may be found at https://www.simplesolution.uk.com/privacy-statement/ and applies to the personal information of its customers, contacts, vendors, and agents, when the GDPR applies to such personal information.

California Residents

California residents have certain rights regarding their personal information under the California Consumer Protection Act (“CCPA”) and other applicable laws. More information about rights for California residents can be found at Rights to Access or by calling us toll-free at 800.690.9908. You can designate an agent to exercise your rights for you. Please note that we will take reasonable steps to verify your identity before implementing your rights request, including asking you to provide identification.

Effective Date and Updates

If we materially change this Data Privacy Notice, we will notify you of the changes. Any changes will be effective immediately upon the posting unless otherwise indicated. Where changes to this Data Privacy Notice will have a fundamental impact on the nature of processing or otherwise have a substantial impact on you, we will give you sufficient notice so that you have the opportunity to exercise your rights.

How to Contact Us

We encourage you to review this Data Privacy Notice in its entirety. Should you have any questions or concerns about our privacy practices, please do not hesitate to contact our Privacy Manager at privacy@companapetbrands.com or write to us at:

Compana Pet Brands LLC
Attn: Privacy Manager
707 Spirit 40 Park Drive

Suite 150
Chesterfield, MO 63005
United States

800.690.9908

DATA PRIVACY NOTICE

This Data Privacy Notice applies to the processing of personal information of all customers, contacts, vendors, and agents of Compana and our brands, as well as all visitors to companapetbrands.com and our other websites (including, but not limited to, doggiedailies.com, mannapro.com, zogaurdplus.com, fruitablespet.com, nutrivet.com, espree.com, naturalcarepets.com, vetsbest.com, simplesolution.com, bagsonboard.com, buffalorangetreats.com, and outpetcare.com), except as specified herein. When we use the term “personal information” in this Data Privacy Notice, we mean information that identifies, or can be used on its own or combined with other pieces of information to identify an individual. This can be, for example, a name, street address, e-mail address, or telephone number(s).

Click on one of the links below to jump to a specific section:

Personal Information We Collect and How We Use It
Information We Collect by Automated Means
How We Share Personal Information
Links to Other Sites
How We Protect Personal Information
Personal Information Retention
International Transfers of Personal Information
Changing and Updating Personal Information
Children
California Residents
Updates to Our Data Privacy Notice
How to Contact Us

Personal Information We Collect and How We Use It

We collect personal information from or about individuals when you purchase products from one of our brands, interact with us through our animal health and nutrition websites, voluntarily provide us with information such as when you submit information through a form on one of our websites or otherwise contact us, and by other means, including from third-parties such as commercial data vendors, and public databases. The principal types of information we collect and reasons for our collection of the information, as well as the ways we may use the information, are listed below.

Business Purposes – On our animal health and nutrition websites, you may be able to register using your personal information in connection with the products and services we offer. We use these details to facilitate your use of the websites and to provide you with products and services that you request. You may also choose to provide, or we may obtain, your personal information at trade shows or from our distributors. It is in our legitimate business interests to use this personal information so that we can manage our business relationships, provide you with products and services you request, and carry out marketing and sales activities.

Careers – Individuals apply for jobs with Compana through our animal health and nutrition websites, third-party job posting sites, job fairs, or directly to various business locations. The personal information job seekers provide through this process is often maintained by third-party service providers. This personal information may be maintained by third parties, accessible to our recruiting team, and shared with our corporate divisions and entities for the purpose of evaluating job seekers for permanent and temporary positions within our company. The personal information submitted by job seekers, such as name, contact details, resume and job history information, and any other information relevant to the application is used to evaluate job seekers’ qualifications for employment and to contact them regarding possible employment opportunities. It is in our legitimate business interests to use this personal information in the selection process and to communicate with job seekers, and it is necessary to provide us with this personal information so that we can evaluate job seekers’ applications.

Marketing Efforts – We may use information that we collect from you or from third parties to send you marketing and sales communications, including via email or text, where you have opted into receiving SMS communications. We send you these communications information to provide you with information about our products and marketing or sales updates that we think you may be interested in. You may unsubscribe or elect to stop receiving marketing communications from us at any time by opting out using the mechanism set forth in the communication (usually, clicking “unsubscribe” or texting “STOP”), or by contacting us using the information set out below in the “How to Contact Us” section.

Contact – You may contact us with questions, requests, or comments through the “Contact” link on each of our animal health and nutrition websites or via the contact information provided in the “How to Contact Us” section of this Data Privacy Notice. When you do so, we may ask you for your personal information to verify your identity or to track the inquiry internally to ensure we appropriately respond to your needs, and you may voluntarily provide your contact information so that we can respond to your inquiry. We also may contact you to provide you with updates about your order or services you have requested from us, or changes regarding the terms and conditions or policies applicable to your use of our website and services.

Contractual Obligations – If you are a vendor or an independent contractor, we may ask you to provide personal information such as your name, contact details, or business and financial details to establish and administer your account, process payments, and for compliance with internal and legal requirements. We use your personal information for this purpose so that we can comply with our contractual obligations to you.

Feedback – You may be able to submit feedback on one of our animal health and nutrition websites. If you choose to give us your feedback, we collect personal information from you. We may also ask you about your experience using our websites. It is in our legitimate business interests to use the personal information you provide to enhance our websites, evaluate the quality of our products and services, or to communicate with you about our products and services.

Information Technology Security – We may collect personal information when detecting and defending against security threats in accordance with our legitimate business interests and our legal obligations. We use various IT tools to detect and defend against online security threats (e.g., attacks, viruses, malware, spam, phishing, malicious web content, etc.), to promote business continuity of our information systems and assets, and to maintain optimal performance of our systems.

Other Uses of Information – We may use personal information for internal general business purposes in accordance with our legitimate business interests. These purposes include administration of our animal health and nutrition websites, data analytics, fraud prevention, and compliance with our legal obligations, standards, policies, and procedures (i.e., due diligence checks and denied party screening, where necessary). At times, we may also collect and use information for other purposes described to you at the time we collect your information. We will obtain your explicit consent to collect and use certain types of personal information when we are required to do so by law.

Information We Collect by Automated Means

When you visit and interact with our animal health and nutrition websites, we may automatically collect information that does not inherently reveal your specific identity but may be considered personal information when combined with other information. We use this information in order to learn how to best tailor our websites for our visitors’ needs, and to provide you with more relevant content such as behavioral targeted advertisements. Examples of this information we and third-party service providers may collect and use this information includes:

Aggregated Information – Aggregated user information does not personally identify you or any other user (for example, we may aggregate user information to calculate the percentage of our users who come from a particular region of the country). Aggregated data is treated strictly in accordance with this Data Privacy Notice.

Browser and Device Information – Certain information is collected by most browsers or automatically through your device, such as your computer type, operating system, name and version, device manufacturer and model, Internet browser type and version, and the name and version of the online services you are using. We use this information to ensure that our animal health and nutrition websites function properly and to secure our websites against cyberattacks and intrusions.

IP Address – Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the online services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, administering our online services, and securing our websites against cyberattacks. We may also derive your approximate location from your IP address to understand which regions of the United States visitors of our animal health and nutrition websites visit from.

Cookies – Cookies are pieces of information stored directly on the computer or mobile device that you are using. Cookies allow us to collect information such as browser type, time spent online, pages visited, products viewed, referring URL, and other aggregated website traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information, and to personalize your experience while online and on one of our animal health and nutrition websites. For more information about our use of Cookies, please visit our Cookie Policy at https://www.mannapro.com/cookie-policy.

Pixel Tags or Similar Technologies – Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some online services to, among other things, track the actions of users of the online services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the online services and response rates. We also use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of our services and report on activities and trends. These services may collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. For more information on our use of these technologies, please visit our Cookie policy at [https://www.mannapro.com/cookie-policy.

How We Share Personal Information

We do not sell, share or otherwise disclose your personal information except as described in this Data Privacy Notice. We share information in the following ways and circumstances:

Business Transfers and Successor Entities – We may disclose your personal information, usage information, and other information about you to parties acquiring part or all of our assets, as well as to attorneys, and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Data Privacy Notice. Also, if any bankruptcy or reorganization proceeding is brought by or against us, your personal information may be considered a company asset that may be acquired by or transferred to third parties.

Corporate Divisions and Sister Entities – We may share the information you provide (such as information about your orders, inquiries, applications, or use of our websites) with our other corporate divisions and sister entities for marketing, recruitment, and internal reporting purposes. We do this to run our business more efficiently and to have a better understanding of our business relationships across the Dogs & Cats, Equine, Poultry, Goat & Sheep, Cattle & Swine, Bird, or Small Animal business lines.

Law Enforcement Agencies, Courts, Regulators, Government Authorities, or Other Third Parties – We may transfer and disclose your information to third parties (i) to comply with a legal obligation, (ii) when we believe in good faith that the law requires it, (iii) at the request of governmental authorities conducting an investigation, (iv) to verify or enforce our policies, procedures, Terms of Use, and other agreements, or to protect the rights, property, or safety of Compana, our customers, vendors, and business partners, or others, including visitors of our websites (v) to respond to an emergency, (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity or (vii) otherwise to protect the rights, property, safety, or security of third parties, users of our products or services, visitors of to our websites, or the public.

Marketing Partners – We may share personal information with third-parties who assist us with our marketing efforts in order to promote our products and to share with you products that you may be interested in. In some cases, we may also permit certain network advertising companies and publishers to collect personal information on our websites. In addition, our business partners may access personal information about you that we have combined with such business partners’ data. We may collaborate with our business partners to jointly send tailored promotional communications to you using the combined set of information. If you prefer not to receive these joint communications or marketing communications from us, you can opt out by following the instructions included in any such communication.

Third-Party Service Providers – In order to carry out your requests, to make various features, services, and products available to you, to respond to your inquiries, and for other purposes described in the “Personal Information We Collect and How We Use It” section of this Data Privacy Notice, we may share your personal information or usage information with third parties that perform functions on our behalf, such as companies or individuals that: host or operate our animal health and nutrition websites; analyze data; provide customer service; mail product samples or manage payments; advertisers; sponsors or other third parties that participate in or administer our promotions, e-commerce activities, job applicant and recruiting resources, or assist with risk management, compliance, legal, and audit functions. These service providers are not authorized to use or disclose the information we share with them except as necessary to perform services on our behalf or to comply with legal requirements, and they are required to keep the information confidential.

Non-Personal Information – We may share non-personal information, such as aggregate user statistics, demographic information, and usage information with third parties.

Sharing With Your Consent – Our products or services may present you with the opportunity to opt in to receive information or marketing offers from third parties or to otherwise consent to the sharing of your information with third parties. If you agree to have your personal information shared, your personal information will be disclosed to the third-party as described to you when you opt-in, subject to the privacy notice and business practices of that third party.

Links to Other Sites

Our animal health and nutrition websites and communications may on occasion provide links to other websites, including to social networks or business partners that may use our logo(s) as part of a co-marketing effort. To the extent that any linked products or services are not provided by Compana or our brands, we are not responsible for the products or services, privacy and data collection, use and sharing practices, or any of the content found on these websites. If you provide information on and use third-party services or websites, the privacy policy and terms of service on those websites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting your personal information, as these third parties have their own collection practices which may be different than those of Compana. Also, please be advised that if you disclose personally information or personally sensitive information through public forums or message boards, this information may be collected and used by others. We do not monitor these public spaces and take no responsibility for the content, security, or confidentiality of any information posted thereon.

How We Protect Personal Information

In proportion to the sensitivity of the information, we maintain reasonable administrative, technical, and/or physical safeguards and appropriate security measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction of personal information. However, we cannot absolutely guarantee the security of personal information, as no electronic data transmission or processing of personal information is completely secure. If we become aware of an incident affecting your personal information, we will investigate and comply with all required reporting obligations.

Personal Information Retention

We will keep your personal information for as long as we have an a relationship with you. Once our relationship with you has come to an end, we will retain your personal information only for a period of time that enables us to:

Maintain business records for analysis and/or audit purposes;
Comply with record retention requirements under the law;
Defend or bring any existing or potential legal claims; and
Address any complaints regarding our products or services.

We will delete your personal information, or de-identify or aggregate your personal information so that it is no longer personally identifiable when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the personal information.

Please note that you have the right to request that personal information collected from you be erased and forgotten before the end of our information retention periods.

International Transfers of Personal Information

Compana is a global organization - headquartered in the United States – that does business in many countries, including the United Kingdom. While Compana has an affiliate entity located in the United Kingdom, Compana does not share or receive consumer data from this entity. However, Compana may share your personal information with our service providers and other business partners, some of which may be located in countries outside of the jurisdiction in which you reside. Although the data protection laws of the jurisdiction in which you reside may differ from those in the jurisdiction to which your information is transferred, we have put in place appropriate safeguards (such as contractual commitments) to ensure that your personal information is handled as described in this Data Privacy Notice and in accordance with the law. For more information on the appropriate safeguards in place, please contact us via the contact information provided in the “How to Contact Us” section of this Data Privacy Notice. If you reside outside of the United States and provide information directly to Compana or visit Compana’s, or and of its brands, United States websites, we rely on your consent to process your data in the United States.

Changing and Updating Personal Information

You have the right to review and correct your personal information that we have received from you. We encourage you to contact us to update or correct your information if it changes or if you believe the personal information we hold about you is inaccurate. Please note that we will likely require additional information from you in order to verify your identity and respond to your requests. If you would like to update or correct your information, please contact us via the contact information provided in the “How to Contact Us” section of this Data Privacy Notice. We will timely respond to your request.

Children

Our products and services are not directed to children under the age of sixteen (16). We do not knowingly collect personal information from anyone under sixteen (16) without parental consent. If you become aware that we have collected personal information from a child under the age of sixteen (16) without parental consent, please let us know so we can take appropriate action.

California Residents

If you are a California resident and have provided us with your personal information, you may ask us to refrain from sharing your personal information with third parties, including our other divisions if they are separate legal entities, for direct marketing purposes. This is known as the right to opt-out of the sale of personal information. If you wish to refrain from this sharing, please contact us via the contact information in the “How to Contact Us” section of this Data Privacy Notice. In addition California residents have the access, deletion, knowledge, opt-out, and portability rights described below. In the event of any conflict between this section on California Residents and the rest of this Data Privacy Notice, this section on California Residents shall prevail.

Personal Information

For purposes of this section on California Residents, “personal information” means “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Cal. Civ. Code § 1798.140(o)(1).

Personal Information Does Not Include

Publicly available information from federal, state, or local government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Categories, Purposes, and Disclosure of Data Collected

The categories and purposes of collection of personal information are described in the section “Personal Information We Collect and How We Use It” above and reflect how we intend to and how we have collected and used information in the twelve months prior to the effective date. The Section “How We Share Your Data” above describes how we intend to and have disclosed personal information in the twelve months prior to the effective date. We will not collect further information or use your personal information for additional purposes without providing you additional notice. The table below sets forth the specific categories of information we have collected from California Residents in the last twelve months, and whether this information was shared with third parties.

Categories of Personal Information collected from California Residents
Category	Examples	Collected	Shared with Third Parties?
A. Identifiers.	A real 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, or other similar identifiers.	Yes	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or 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. Some personal information included in this category may overlap with other categories.	Yes	Yes
C. Protected classification characteristics under California or federal law.	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, veteran or military status, genetic information (including familial genetic information).	Yes	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes	Yes
G. Geolocation data.	Physical location or movements.	Yes	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No	No
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	Yes

We may not collect all of the personal information listed in the “examples” column from each individual who interacts with us.

Use of Personal Information of California Residents

The section “Personal Information We Collect and How We Use It” above reflects how we intend to and how we have used personal information of California residents in the twelve months prior to the effective date. 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.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose (which we have done in the preceding twelve (12) months), we enter a contract that describes the purpose and prohibits the recipient from (a) selling the personal information; (b) retaining, using, or disclosing the personal information for any purpose other than for the specific business purpose specified in the contract; and (c) retaining, using, or disclosing the information outside of the direct business relationship with us. The table above reflects the categories of personal information that we intend to disclose and have disclosed in the preceding twelve (12) months.

We disclose your personal information for a business purpose to the following categories of third parties:

Our divisions, affiliates and sister entities.
Service providers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not “sold” any personal information in the traditional sense of the word. We have, however, provided personal information to network advertising companies and publishers in exchange for their assistance with our marketing efforts in order to provide you with more relevant advertisements. This may constitute a “sale” of data per California’s definition of a sale. Using the categories set forth in the table above, we have “sold” the following categories of personal information in the last twelve months:

Category	Examples
A. Identifiers.	A real 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, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or 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. Some personal information included in this category may overlap with other categories.
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.	Physical location or movements.
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Rights to Access, Knowledge, and Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable California consumer request, we will disclose to you, as it pertains to the (12) twelve months prior to the request:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our legitimate 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).
If we sold or disclosed your personal information for a legitimate business purpose, in 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.

Rights to Deletion

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable California consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a product 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.
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 are 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.

Opt-out of the Sale of Personal Information

As of January 1, 2020, California consumers have the right to opt out of the sale (or disclosure for other valuable consideration) of personal information about them or their household, such as (though not limited to) their name, postal or email address, and other personally identifying information.

This right is subject to certain exemptions. For example, the law does not apply to information that has been aggregated and/or de-identified such that it could not reasonably be used to identify you. It also does not apply to information that we share with third-party service providers in order for them to perform certain business functions for us.

If you would like to opt out, you may use the “Do Not Sell My Information” button, or by calling us at 800.690.9908, or by writing us at privacy@companapetbrands.com.

While it is not our present intention to sell personal information of children under the age of sixteen (16), children between the ages of thirteen (13) and sixteen (16) may affirmatively opt-in to the sale of personal information. Children below the age of thirteen (13) may only consent to the sale of personal information with parental consent. For more information on information collected from children generally, please visit the “Children” section above.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, knowledge, data portability, deletion, and opt-out rights described above, please submit a verifiable consumer request to us by either by calling us at 800.690.9908, or by writing us at privacy@companapetbrands.com.

Only you or (a) a natural person that you authorize to act on your behalf or (b) a business entity registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent to submit a request on your behalf, we will require that you provide written evidence that you have granted the authorized agent permission to make such a request, and we will verify your identity.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. Making a verifiable California consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you products or services.
Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of products or services.
Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.

However, we may charge you a different price or rate, or provide a different level or quality of products or services to you, if that difference is reasonably related to the value provided to you by the use of your personal information.

Response Timing and Format

We will confirm receipt of a California consumer request within ten (10) days of receipt and provide information regarding how we will process the request. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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.

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.

Updates to Our Data Privacy Notice

We may modify or update this Data Privacy Notice from time to time. We will always indicate at the top of this policy when it was most recently updated. If we materially change this Data Privacy Notice, we will endeavor to notify you of the changes. Any changes will be effective immediately upon the posting unless otherwise indicated. Where changes to this Data Privacy Notice will have a fundamental impact on the nature of processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights.

How to Contact Us

If you have any questions or comments about this Data Privacy Notice or if you would like us to update information we have about you or your preferences, contact our Privacy Manager at privacy@companapetbrands.com or call or write to us at:

Compana Pet Brands LLC
Attn: Privacy Manager
707 Spirit 40 Park Drive
Chesterfield, MO 63005
United States
800.690.9908

Last Updated 6/3/2022