Privacy Policy

Last Updated: May 13, 2024  

Caruso Foods, LLC, doing business as Caruso Brands (”Caruso Brands” or “We”), and this Privacy Policy sets forth the terms and conditions with respect to how we process personal information about you (hereinafter “you” or “your”) and other third parties. This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information. This Privacy Policy applies to the personal information you provide us when you visit any of our websites (collectively, the “Site”), purchase or receive products, goods, or services from Caruso Brands, apply for a job with Caruso Brands, or otherwise contact or engage with us. For purposes of this Privacy Policy, the Site and all products, goods and services furnished by Caruso Brands shall be referred to collectively as the “Services.”  

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND THE CARUSO BRANDS TERMS OF SERVICE, COOKIE POLICY, and CONSUMER HEALTH DATA PRIVACY POLICY EACH BEING INCORPORATED INTO, AND FORMING AN INTEGRAL PART OF, THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AND THE CARUSO BRANDS TERMS OF SERVICE, COOKIE POLICY, AND CONSUMER HEALTH DATA PRIVACY POLICY,  YOU SHOULD NOT USE CARUSO BRAND’S SERVICES, AND YOU SHOULD LEAVE THE SITE IMMEDIATELY AND NOT PROVIDE CARUSO BRANDS WITH ANY PERSONAL INFORMATION.  

You must be at least eighteen (18) years of age to access the Services. Caruso Brands is headquartered in the United States, and the personal information you provide to Caruso Brands may be processed and stored in the United States. For more information on our data transfer practices, please see Section 9 (Data Retention and Localization). For more information with respect to how we collect and use Consumer Health Data, please see our Consumer Health Data Privacy Policy. 

  1. Scope 

This Privacy Policy applies to personal information that Caruso Brands receives during its business operations. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and is not otherwise subject to a data protection law, statute, or regulation. Caruso Brands may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and Caruso Brands may use such data for any purpose.  

  1. The Types and Categories of Personal Information We Collect 

Caruso Brands collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to Caruso Brands, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:  

Personal Information 
Category   Description/Examples  
Personal Identifiers   Identifiers, such as your name, alias, shipping address, email address, account name, telephone number, customer identification number.  
Registration Data   Information provided when you register for an account to use the Site, including usernames and passwords.  
Online Identifiers (For more information, see “Technical Data” below)   Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.  
Commercial Information   Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services.  
Health Data  You may furnish us with health-related information in the event you, or a third party, has an adverse reaction to the use of our products or goods. For more information with respect to how we collect and use Consumer Health Data, please see our Consumer Health Data Privacy Policy. 
Marketing and Communications Data   Information with respect to your marketing preferences and your subscriptions to our publications and alerts.  
Internet and Electronic Network Data   Data pertaining to your access or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites.  
Your Feedback   Information you provide about our Services, which may include data gathered from any Caruso Brands surveys or reviews submitted by you.  
Geolocation Data   Information about the general city, state, or region in which a user of the Site is located.  
Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)   If you apply for a job with Caruso Brands, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.  
Inferences   Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.  
  1. Technical Data 

When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, and your experience on the Site and other websites, including the following:  

Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.  

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. For more information, see our Cookie Policy 

Site Monitoring. Please be aware that we, and our third-party service providers and partners, use Cookies and Other Tracking Technologies within the Site to monitor and record any and all activities and communications to, from, and on, the Site in order to safeguard, improve, and analyze usage of, the Site, and for the other purposes listed in our Privacy Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording by us and our third-party service providers and partners. 

Non-Cookie Technologies. We may deploy on our Site certain types of “Non-Cookie Technologies” provided by our service providers to support our digital advertising programs.  These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically or with additional data specifically requested from your browser or device. For more information, see https://thenai.org/wp-content/uploads/2021/07/NAI_BeyondCookies_NL.pdf.  

  1. Sources of Information 

We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Site, and from third parties. More specifically, we collect personal information from the following sources:  

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., account registration, completing purchases, signing-up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.  

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).  

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references.  

  1. How We Use your Information / Purpose of Collection 

We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests. 

 How Your Personal Information Is Used 
Provide, operate, maintain, improve, and promote our Services, including optimization of offerings presented to you. 
Enable you to access and use our Services and fulfill your transactions. 
Process and complete transactions, and send you related information, including purchase confirmations and invoices. 
Send you messages and communications related to our Services (e.g., responses to your comments, questions, and requests, customer services). 
Furnish technical notices, updates, security alerts, and support and administrative messages to you about our Services. 
Provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, and events). 
Research, monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests. 
Investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, Site cybersecurity, and other illegal activities. 
Personalize our Services, including providing features or advertisements that match your interests and preferences. 
Caruso Brands may collect and use your personal information for any other purpose for which we obtain your consent. 

 

6.   Sharing Information / Third-Party Disclosures 

We share your personal information as described below and in this Privacy Policy, and as permitted by applicable law. 

Category of Recipient  Purpose of Disclosure 
Intra-Group  We may share your personal information with our parent company, and our affiliates, and subsidiaries. 
Service Providers  We share personal information with third parties in connection with the delivery of our Services (e.g., credit card processing, customer service, business analytics, fraud prevention, legal compliance services, and advertising and marketing). 
Business Partners  We may share your personal information with third parties that distribute our products and marketing materials. 
Business Restructuring  Circumstances may arise where, for strategic or other business reasons, we decide to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of our assets. 
Legal; Compliance; Legitimate Interests  We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, we may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. 
Consent  In addition to the reasons for disclosure set forth herein, we may also disclose your personal information upon your consent. 

 

In the event that you facilitate a transaction with Caruso Brands or request information from or otherwise engage with us, and such activities require Caruso Brands to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct Caruso Brands to intentionally disclose your personal information to the service provider or third party. 

  1. Social Media/ Platform Data Rights 

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, and the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.  

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified.  If you would like Platform Data related to you deleted or modified, please contacts us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.  

  1. Links to Other Websites; Your Direct Third-Party Disclosures 

As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.  

  1. Data Retention and Localization 

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information for as long as needed to provide you with our Services, to facilitate transactions you have requested, to comply with our legal obligations (e.g., tax filings), to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy. 

Caruso Brands is based in the United States, and the personal information that we collect and process is retained and stored in the United States. Caruso Brands uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in such other third countries. 

  1. Security 

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.  

  1. No Data Collected from Children 

The Site is not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under eighteen (18) years of age without verified consent from their parents or guardians. If you are under the age of eighteen (18), you are prohibited from accessing or using the Services (including the Site) or with providing us with your personal information.  

  1. Publicly Posted Information; Product Reviews 

The Site may provide you with the ability to submit a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”) or provide other information on the Site which may be posted to a publicly available portion of the Site. Any information or content you post in a Product Review will be available to other users of the Site and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part and we recommend you carefully consider the information you choose to make publicly available.  

  1. Your Responsibilities 

You are permitted, and hereby agree, to only provide personal information to Caruso Brands if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO CARUSO BRANDS, YOU EXPRESSLY REPRESENT AND WARRANT TO CARUSO BRANDSTHAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE CARUSO BRANDS ITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT CARUSO BRAND’ USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY CARUSO BRANDS OR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO CARUSO BRANDS. 

  1. Updating Your Information 

It is important that the personal information that you provide to us is accurate and reliable. You have the ability to update your personal information at “checkout” when you purchase a good or product. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address) and you must do so, when such changes are warranted. If your account does not contain such features, then you must directly notify Caruso Brands of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.  

  1. Email Marketing and Your Rights 

You have the right to opt-out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify Caruso Brands, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.  

  1. 17. Your Privacy Rights

Depending on applicable law, you may be entitled the following data privacy rights and privileges: 

 

  • Right to Know. You may have the right to know about what personal information Caruso Brands collects and processes about you, including the types and categories of personal information we collect and process, the sources of such personal information, our retention criteria, with whom we share your personal information, cross-border data transfers, and how to file complaints and inquiries. 
  • Access Rights. You may have the right to ask us whether we process any of your personal information and, if so, receive access to such personal information. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal information concerned as well as any other information necessary for you to exercise the essence of this right. 
  • Rectification. You may have the right to have your personal information corrected/rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal information about you and, taking into account the purposes of the processing, update any incomplete personal information, which may include the provision of a supplementary statement. 
  • Erasure. You may have the right to have your personal information erased, which means the deletion of your personal information by us. However, your right to erasure is subject to statutory limits and prerequisites (e.g., where your personal information is no longer necessary in relation to the initial purposes for which it was processed, your personal information was processed unlawfully). 
  • Restriction of Processing. You may have the right to obtain the restriction of the processing of your personal information, which means that we suspend the processing of your personal information for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal information is contested, but we need time to verify the inaccuracy (if any) of your personal information. 
  • Data Portability. You may have the right to request we provide you with your personal information in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. 
  • Right to Object. You may have the right to object to the processing of your personal information, which means you may request we no longer process your personal information. This only applies in case the “legitimate interests” ground (including profiling) constitutes the legal basis for processing (see below “Legal Basis for Processing”). However, at any time (and free of charge) you can object to having your personal information processed for direct marketing purposes. 
  • Automated Decision Making. You may have the right to object to having us use your personal information to conduct automated decision making. However, Caruso Brands oes not engage in any activity that subjects our customers, website users, survey participants, or others to a decision based solely on automated processing, including profiling, which produces legal effects, or similarly significant results, impacting them. 
  • Withdrawing Consent. You also may withdraw your consent at any time if we are solely relying on your consent for the processing of your personal information. However, this will not impact our legal basis to process such personal information prior to the withdrawal of your consent. 
  • Do Not Share/Targeted Advertising Rights. You may have the right to opt out from having us disclose your personal information to third parties for targeted advertising purposes. This is sometimes referred to as the right to opt-out of the “sharing” of personal information for cross-contextual behavioral advertising purposes. To prevent your personal information from being used in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the site to set your cookie preferences.  

 

We will facilitate your exercise of the rights that apply to you in accordance with applicable law. However, even if your personal information is not afforded protection under, or otherwise subject to, a data protection law, we may seek to accommodate any request or inquiry you may have with regard to our data processing activities. If you have questions about your rights or wish to exercise your rights, you can contact us at Contact@CarusoBrands.com, or otherwise in accordance with the “Contact Us” section listed below. 

 

  1. 18. Privacy Appeals; Complaints

In certain jurisdictions, you may have the right to appeal a decision Caruso Brands has made with respect to your privacy request. To submit a privacy rights decision appeal, please email us at Contact@CarusoBrands.com with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review.  

 

Depending on applicable law, you may have the right to submit a complaint to a data protection authority responsible for overseeing our compliance with data protection law in your jurisdiction. Please see a list of potentially applicable regulatory authorities: 

 

 

We would, however, appreciate the opportunity to address your concerns, so please feel free to contact us regarding any complaint you may have. We will not discriminate against individuals for exercising their data privacy rights or filing a privacy complaint.  

 

  1. 19. Legal Basis for Processing (EEA/UK/Switzerland Only)

 

For purposes of the EU/UK GDPR, we can collect and process your data under one of the following legal bases: 

 

  • Consent. We can collect and process your data with your consent. For example, if you have given your consent to receiving marketing material from us at the point we collected your information. 
  • Contractual Obligations. We need your personal information to comply with our contractual obligations. For example, if you have subscribed to one of our services, we use your personal information to fulfill, and deliver that service to you. 
  • Legal Compliance. If the law requires us to, we may need to collect and process your data. 
  • Legitimate interest. We may use your data as required in the normal course of operating our businesses and services unless our legitimate interests are overridden by your rights. 
  • Vital interests. We may need to process your personal information if the processing is necessary to protect your vital interests (for example, health and safety reasons if you attend a meeting at a Caruso Brands location). 
  1. 20. Do-Not-Track Signals 

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.  

  1. 21. Persons with Disabilities 

Caruso Brands strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.  

  1. 22. Rewards Programs and Financial Incentives 

We collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs (“Rewards Programs”). We use the personal information you provide in these programs to verify your identity, offer unique rewards, track your program status, and facilitate the exchange of program points for products, promotional materials, training workshops, and other items. If you consent to participate in any of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the “Contact Us” section listed below or in accordance with the instructions set forth in the applicable Rewards Program’s terms and conditions. Caruso Brands may use personal information gathered from, or related to, participants in our Rewards Programs for any other purpose or in any other manner set forth in this Privacy Policy.  

California Rewards Program Rights. Pursuant to the CCPA, you may be entitled to be informed as to why financial incentive programs, or price or service differences, are permitted under the law, including (i) a good-faith estimate of the value of your personal information that forms the basis for offering the financial incentive or price or service difference, and (ii) a description of the method we used to calculate the value of your personally information. Generally, we do not assign monetary or other value to personal information. However, in the event we are required by law to assign such value in the context of Rewards Programs, or price or service differences, we have valued the personal information collected and used as being equal to the value of the discount or financial incentive provided, and the calculation of the value is based upon a practical and good-faith effort often involving (i) the categories of personal information collected (e.g., names, email addresses), (ii) the transferability of such personal information for us and our Rewards Programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our Rewards Programs, and (v) the product or service to which the Rewards Programs, or price or service differences, apply. The disclosure of the value described herein is not intended to waive, nor should it be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.  

  1. 23. Employment Applications and Talent Management 

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and, information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.  

  1. 24. Events and Video Teleconferencing 

Caruso Brands may host and use video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We may use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.  

  1. 25. Changes to the Policy 

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.  

  1. 26. Contact Us 

If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact our us at: (email) Contact@CarusoBrands.com, (mail) Caruso Brands ATTN: Privacy Rights to 6100 W Snowville Rd. Brecksville, OH 44141