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PRIVACY POLICY

We know you care how information about you is used and shared, and we appreciate your trust that we will do so sensibly. By visiting Conohotsauce.com or any other site owned by Orionlist Company or its subsidiaries (collectively, the “Company,” “we,” “us,” or “our”) that links to this notice (collectively, the “Websites”), you are accepting the practices described in this Privacy Notice. If you are a California resident, please be sure and review the section of this Policy that is addressed specifically to you.

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WELCOME!

This notice is designed to answer frequently asked questions about your online privacy, including what personally identifiable information we may obtain from you and how we may use it. It describes our privacy policy for United States visitors. 

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WHAT PERSONAL INFORMATION ABOUT VISITORS DO THE WEBSITES GATHER?

1. INFORMATION WE COLLECT

We collect information that identifies or that could be linked, directly or indirectly, with a particular consumer or a device that the consumer uses (”personal information”).  In particular, within the last twelve (12) months, via the Websites we have collected personal information falling within the below-listed categories marked “YES”, and we have not collected personal information within the categories marked “NO”:

CategoryExamplesCollected

A. Identifiers.Real NameYES

AliasNO

Postal AddressYES

Online IdentifierYES

Internet Protocol (IP) AddressYES

Email AddressYES

B. Personal information categories (as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).NameYES

SignatureNO

Social Security NumberNO

Physical Characteristics or DescriptionNO

Telephone NumberYES

Passport NumberNO

Driver’s License or State Identification Card NumberNO

C. Protected classification characteristics under California or federal law.Age (40 years or older)YES

Race, Color, Ancestry, National OriginNO

CitizenshipNO

Religion or CreedNO

Marital StatusNO

Medical ConditionNO

Sex (including Gender, Gender Identity, Gender Expression, Pregnancy or Childbirth and Related Medical Conditions)YES

Sexual OrientationNO

D. Commercial Information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YES

E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, e.g., fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NO

F. Internet or other similar network activity.Browsing history, search history, information regarding a consumer’s interaction with a website, application, or advertisementYES

G. Geolocation data.Physical location or movements.NO

H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.YES

I Professional or employment-related information.Current / past job history, performance evaluationsYES

Personal information does not include:

  • Publicly available information from government records.

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, like:

    • 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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2. SOURCES OF INFORMATION WE COLLECT

For each of the information categories marked “YES” in the table above (categories of information that we have collected), we obtain the personal information in the following ways:

  • Directly from you (for example, from forms you complete on our website); 

  • Indirectly from you (for example, from observing your actions on our website or interactions with our advertisers); and 

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3. PURPOSE OF COLLECTING AND USE OF PERSONAL INFORMATION WE COLLECT

Our purpose for collecting personal information, and use and/or sharing of this information, are as follows:

  • To fulfill or meet the reason you provided the information. 

    • For example, if you share your name and contact information to ask a question about our products, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or to process returns efficiently.

  • To provide you with support and to respond to your inquiries

    • This may also include investigating and addressing your concerns and monitoring and improving our responses.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • For other reasons as we will relate them to you before we collect your personal information.

We will not collect additional categories of personal information or use the personal information we collected for substantially different purposes, or for unrelated purposes, without first providing you with notice and prior to collecting the information for the different purpose.

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4. SHARING PERSONAL INFORMATION

We have, within the last 12 months, occasionally disclosed personal information to third parties for a business purpose. When we have disclosed personal information to a third party, we have entered into a written agreement with that recipient third party that describes the business purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the agreement. Each third-party agreement also provides that the recipient is not authorized to resell the information unless you (the consumer) have received explicit notice and an opportunity to opt-out of any such transfers. The following categories of personal information may have been disclosed to third parties in the last 12 months:

CategoryExamplesCollected

A. Identifiers.Real Name/YES

Alias/NO

Postal Address/YES

Online Identifier/YES

Internet Protocol (IP) Address/NO

Email Address/YES

B. Personal information categories (as listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Name/YES

Signature/NO

Social Security Number/NO

Physical Characteristics or Description/NO

Telephone Number/YES

Passport Number/NO

Driver’s License or State Identification Card Number/NO

C. Protected classification characteristics under California or federal law.Age (40 years or older)/NO

Race, Color, Ancestry, National Origin/NO

Citizenship/NO

Religion or Creed/NO

Marital Status/NO

Medical Condition/NO

Sex (including Gender, Gender Identity, Gender Expression, Pregnancy or Childbirth and Related Medical Conditions)YES

Sexual Orientation/NO

D. Commercial Information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies./YES

E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, e.g., fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data./NO

F. Internet or other similar network activity.Browsing history, search history, information regarding a consumer’s interaction with a website, application, or advertisement/YES

G. Geolocation data.Physical location or movements./NO

H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information./NO

I. Professional or employment-related information.Current / past job history, performance evaluations/NO

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

  • Our affiliates.

  • 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.

Finally, Orionlist does not share or sell – and has not shared or sold – the personal information of minors under 16 years of age [without affirmative authorization].

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5. YOUR RIGHTS AND CHOICES

California residents have specific rights under the CCPA with regard to your personal information. This section describes your CCPA rights and explains how you may exercise those rights.

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ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. If you make such a request, after we verify your identity, we will disclose to you:

  • The categories of personal information we have 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);

  • If 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.

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DELETION REQUEST RIGHTS

You have the right to request that we delete any of your personal information that we collected from you and have kept, subject to certain exceptions. Once we receive your request, and after verifying it, we will delete (and direct our service providers to delete) your personal information from our records, unless a statutory exception applies. The exceptions:   We may deny your deletion request if we (or our service provider) need to retain the information to:

  • Complete the transaction for which we collected the personal information

  • Provide a good or service that you requested

  • Take reasonable actions in connection with our ongoing business relationship with you

  • Perform any agreement we may have with you

  • Detect security incidents

  • Protect against malicious, deceptive, fraudulent, or illegal activity

  • Prosecute those responsible for such activities

  • Debug products to identify and repair errors that impair existing intended functionality

  • Exercise or to permit the exercise of rights provided by law, including the free speech rights

  • 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 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.

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EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending an email to support@conohotsauce.com

Only you or a person 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. 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 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.

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RESPONSE TIMING AND FORMAT

We will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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 our receipt of the verifiable consumer request.   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.

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6. PERSONAL INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”).  We do not collect or sell the personal information of consumers we actually know are less than 16 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by sending us an email on support@conohotsauce.com

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 visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

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7. 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 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.

  • 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 levels. Any CCPA-permitted financial incentive we offer 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. 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 us an electronic message through our website or write us at our address listed on our webpage.

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8. CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Websites and update the notice’s effective date. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.

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QUESTIONS?

You may contact us at support@conohotsauce.com.

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