Last updated: December 21, 2023

INTRODUCTION

Back to Nature Foods, LLC (hereafter, "Back to Nature") recognizes the importance of protecting your privacy and knows that you care about how your Personal Information (as defined below) is used and/or shared. Back to Nature's intent in collecting Personal Information is to balance its legitimate business interests against the reasonable expectations of privacy of its customers. Back to Nature has adopted this Privacy Policy to inform you how Back to Nature collects, stores, and uses Personal Information that you provide through your interactions with Back to Nature via email, telephone, social media, or the websites where this policy is posted (collectively the “Back to Nature Website”). This Privacy Policy will also tell you about the privacy rights you may have and how the law protects you. We use the term “Personal Information” to refer to any information that identifies, relates to, or describes an identified or identifiable natural person.

Residents in the European Economic Area (“EEA”), Switzerland, United Kingdom (“UK”), California, Colorado, Connecticut, and Virginia should refer to the body of this Privacy Statement as well as the "Jurisdiction-Specific Notices" section below for additional information that may be applicable to them.

Acceptance of this Statement of Privacy

By accessing and using the Back to Nature Website and our services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your Personal Information, we will ask for your consent to the collection, use, and disclosure of your Personal Information as described further below. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of the Back to Nature Website.

U.S. Based Organization

Back to Nature Foods, LLC is headquartered in the United States and our data processing mostly happens in the United States.

COLLECTION OF PERSONAL INFORMATION

To enable Back to Nature to provide you with requested information, market to you, provide special offers and drawings, and respond to consumer requests and complaints, Back to Nature may collect Personal Information from you when you use the Back to Nature Website. Back to Nature collects Personal Information whenever you use the store locator feature, register to receive our emails, register for any services, provide ratings or reviews of Back to Nature products or recipes, or sign up for and participate in promotions and special offers, or drawings offered by Back to Nature. Back to Nature may also collect Personal Information when you contact us, use our social media sites, or attend our live events.

The Personal Information we collect includes personal identifiers (such as your name, email address, social media name), contact information (such as your zip code when you search for a product in your area, address, telephone number); the content of your communications with us; commercial information (such as the products you purchase or obtained or purchasing history or tendencies); geolocation information (such as when you use the store locator functionality) and health information (such as allergy information you provide when you contact us with a comment or complaint), which may be considered sensitive Personal Information in certain jurisdictions. Back to Nature may also automatically collect information, related to your usage of the Back to Nature Website including personal identifiers (such as your IP address) and Internet or other electronic network activity information (such as browser type, originating domain names, access times and referring website addresses). See our Cookie Policy for further information.

For our business contacts, we may receive your contact information, such as your personal identifiers (including your name, telephone number, and email address) and/or professional or business-related information (including your business address), through our online or offline interactions with you, such as when we work together on a project or discuss opportunities to work together. We may send you emails or call you with information about our business dealings, news, or marketing information to communicate with you for business purposes.

HOW WE USE YOUR PERSONAL INFORMATION

Back to Nature uses Personal Information for: marketing and promotional purposes (for example, offering Back to Nature Website users the opportunity to: receive information, participate in special promotions and acquire Back to Nature promotional products, or receive marketing emails whether from Back to Nature or by its business partners and independent contractors); developing enhancements to the Back to Nature Website; in connection with insurance matters in relation to consumer complaints; and evaluating Back to Nature Website usage, including by analyzing usage data in the aggregate.

Additionally, Back to Nature uses Personal Information to direct e-mail to Back to Nature Website users who register with Back to Nature or otherwise provide their e-mail addresses to Back to Nature regarding specific promotions, updates, and service enhancements, and other appropriate or necessary communications via email, telephone, social media, or live events.

SHARING YOUR PERSONAL INFORMATION

Back to Nature may share and disclose your Personal Information with, or collect or use your Personal Information through, our parent, affiliates, associates, agents, suppliers, service providers marketing providers, and such other third parties as Back to Nature, acting reasonably, may deem necessary for the fulfillment of the purposes listed above or where otherwise permitted by law.

Back to Nature may also share your Personal Information: (1) conform to legal requirements or comply with legal process; (2) protect and defend the rights or property of Back to Nature or its affiliated companies; (3) enforce the terms or use; or (4) act to protect the interests of its users and customers. Back to Nature's performance of this agreement is subject to existing laws and legal process, and nothing contained in this agreement is in derogation of Back to Nature's right to comply with governmental, court and law enforcement requests or requirements relating to your use of the Back to Nature Website or information provided to or gathered by Back to Nature with respect to such use.

Back to Nature may also disclose any Personal Information about you as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of our business or assets.

Back to Nature may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

SECURITY OF PERSONAL INFORMATION

Safeguarding personal information is important to us. While no systems, applications, or websites are 100% secure, Back to Nature takes reasonable and appropriate steps to help protect personal information from unauthorized access, use, disclosure, alteration, and destruction. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. Such agents and contractors will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality.

DATA RETENTION

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances you can ask us to delete your data: see the “Privacy Rights” section below for further information.

COOKIES, WEB BEACONS, SIMILAR TECHNOLOGIES

Cookies. A cookie is a small text file that is sent by a website to your computer or device where it is stored by your web browser. Cookies may store information such as your IP address or other identifier, your browser type, and information about the content you view and interact with on digital services. By storing such information, cookies can remember your preferences and settings for online services and analyze how you use online services. First-party cookies are those set by a website that is being visited by the user. An example would be the cookies placed by Back to Nature when you visit the Back to Nature Website. Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. For example, if a user visits the digital services and another entity sets a cookie through our website, this would be a third-party cookie. Please see the Cookie Policy for more information.

Most web browsers are set to automatically accept cookies, but you can control and manage cookies using your browser. You can learn how to manage cookies in our Cookie Policy. Please note that removing or blocking cookies can impact your experience on the Back to Nature Website and some functionality may no longer be available.

Please see our Cookie Policy for information about the collection and use of Personal Information by third-parties who process information collected by cookies and related technologies that we permit them to use on the Back to Nature Website.

Web Beacons. Web beacons or pixel tags are small images which are embedded into the Back to Nature Website that provide us with information about your browser or device, or whether you open or click on the emails we send you. This information is used to help our website and app publishers better analyze and improve their services to us.

Do Not Track. This is a feature used by some browsers to send a signal to websites to indicate that the browser should not be tracked, which will cause cookies used for purposes such as analytics and advertising to be disabled. As there are presently no current industry-wide uniform agreed and accepted standards on how DNT requests should be managed, currently we will not respond to any DNT signals, unless required by applicable law.

INTERNATIONAL TRANSFERS

We may, directly or indirectly through third-party entities around the world, process, store, and transfer the information you provide, including your Personal Information, as described in this Privacy Policy. Specifically, the information and Personal Information that we collect may be transferred to, and stored at, a location outside of your jurisdiction. It may also be processed by staff operating outside of your jurisdiction who work for us or for one of the organizations outlined in this Privacy Policy in connection with the activities outlined in this Privacy Policy. We have put in place commercially reasonable technical and organizational measures to safeguard the information and Personal Information we collect on the Back to Nature Website, to the extent required by applicable law. If we transfer your Personal Information out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms as required by applicable law to lawfully transfer data across borders to ensure that your Personal Information is protected.

PRIVACY POLICIES OF THIRD-PARTY WEBSITES

The Back to Nature Website may contain hyperlinks to third party websites, and while Back to Nature makes all reasonable efforts to hyperlink to websites that share our high standards and respect for privacy, Back to Nature does not control and is not responsible for the content or the privacy practices of third-party websites. As such, Back to Nature encourages you to review the privacy statements of websites you choose to link to from the Back to Nature Website so that you can understand how those websites collect, use and share your information.

NO USE BY CHILDREN

Our services and the Back to Nature Website are not intended for children under 16 years of age. We do not intentionally gather Personal Information about individuals who are under the age of 16. Moreover, individuals under 18 years old are not allowed to register for our contests, newsletter, clubs or activities. We do not knowingly collect, maintain, or use data about individuals who are under the age of 16. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under the age of 16, please contact use at complianceamericas@barilla.com. Also, if we learn that any information has been posted by a child, we will promptly delete that information.

CHANGES

Back to Nature reserves the right to change this Privacy Policy at any time. We will post any Privacy Policy changes on this page and if we make material changes to this Privacy Policy, we will notify you by email or through a notice on the Back to Nature Website.

CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, you may contact us by one of the following methods:

• Call: Back to Nature - 1-855-346-2225
• Email: complianceamericas@barilla.com
• Write:

Back to Nature Foods, LLC
c/o Barilla America, Inc.
Attn: Compliance Americas 885 Sunset Ridge Rd.
Northbrook, IL 60062

PRIVACY RIGHTS

Certain jurisdictions have specific legal requirements and grant privacy rights with respect to Personal Information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to: (1) obtain a copy of Personal Information we maintain about you in a portable format; (2) correct inaccuracies or incompletion in your Personal Information; (3) object to the continued processing or use of your Personal Information; (4) complain to a supervisory authority; (5) or request that Personal Information be blocked, anonymized or deleted. You may also have the right to not be discriminated against for exercising your privacy rights. If you are a California, Colorado, Connecticut, Virginia, EEA, Switzerland, or UK resident, see our "Jurisdiction-Specific Notices" section below for additional information as to how to exercise rights under the laws of those jurisdictions. If you are located outside that jurisdiction and seek to exercise your rights under the law of another jurisdiction, please contact us by emailing complianceamericas@barilla.com.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. When you make a request, we may also contact you to ask you for further information in relation to your request to speed up our response and require you to follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on your jurisdiction and the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.

We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event.

JURISDICTION-SPECIFIC NOTICES

EEA, Switzerland, or UK Residents

Back to Nature believes that it is important that individuals are given the opportunity to exercise choice with respect to how their Personal Information is collected and used. Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), provide you with certain rights in connection with Personal Information you have shared with us.

If you are resident in the EEA, Switzerland, or the UK, you have the following rights:

The right to be informed. You are entitled to be informed of the use of your Personal Information. This Privacy Policy provides such information to you.

• The right of access. You have the right to request a copy of your Personal Information which we hold about you.
• The right of correction: You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
• The right to be forgotten: You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
• The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
• The right to data portability: You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy, or transmit your Personal Information stored on our servers / IT environment to another service provider’s servers / IT environment.
• The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
• The right to lodge a complaint with a supervisory authority. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.

To access these rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-855-346-2225
• complianceamericas@barilla.com.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Information about you in order to provide our services or our websites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.]

California Residents

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the "CCPA"), California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.

Except as indicated in the "Collection of Personal Information" section, we do not seek to collect any additional "sensitive personal information" (as defined in the CCPA). The chart below described the categories of Personal Information Back to Nature has collected in the preceding 12 months, the sources and purpose of such collection, and the parties to whom the information was shared for business purposes:

Personal Information Category (corresponds to categories in CCPA

§1798.140(o)(1)) (*

may constitute "sensitive personal information" under the CCPA)

Sources of Personal Information and Why We Collect this Information

Criteria used to determine retention periods

Sold or Shared

Disclosure of Personal Information to

Identifiers (such as name, online identifier, Internet Protocol address, email address, social media username, Social Security number, passport number, driver's license number)*

Information you provide us— complete a consumer contact request, register you for an account, operate our special offers and drawings, marketing

The duration of our relationship with you; the length of time necessary to complete a special offering or drawing; whether your Personal Information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data.

Sold and shared (Back to Nature only "sells" Personal Information in connection with cookies and similar technologies)

Service providers - professional advisors - our affiliates - marketing providers

Internet or other similar network activity (such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement)

Information we collect from you automatically— in order to monitor and improve the performance of the Back to Nature Website, fraud prevention, marketing

Same as above.

Sold and shared

Service providers - professional advisors - our affiliates - marketing providers

Privacy Rights of California Residents

Under the CCPA, a California resident has the following rights: (1) to request additional information about our data collection, use, disclosure, and sales practices in connection with your Personal Information; (2) to request the specific Personal Information collected about you during the previous 12 months; (3) to request the deletion of the Personal Information we have about you; (4) to request a restriction on certain processing of Personal Information; and (5) to request correction of inaccurate information. You may not be discriminated against for exercising your California privacy rights.

To exercise these rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-855-346-2225

Emailing us at complianceamericas@barilla.com

You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.

Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete Personal Information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.

We will aim to respond to your request as soon as reasonably practicable and consistent with any applicable laws. If we require more time, 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. In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

California residents are also entitled to contact us to request information about whether we have disclosed Personal Information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt- out of the sharing of your Personal Information with third parties for marketing purposes. To make such a request you should send (a) an email to complianceamericas@barilla.com. with the subject heading “California Privacy Rights,” or (b) a letter addressed to:

Back to Nature Foods, LLC
c/o Barilla America, Inc.
Attn: Privacy Inquiry Compliance Americas 885 Sunset Ridge Rd.
Northbrook, IL, 60062 U.S.A.

In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

Colorado Residents

Colorado residents have certain rights around Back to Nature’s collection, use, and sharing of their Personal Information. Back to Nature sells your Personal Information; however, Back to Nature only "sells" Personal Information in connection with cookies and similar technologies. Back to Nature does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Back to Nature engages in “targeted advertising” as that term is defined in the Colorado Privacy Act ("CPA").

Back to Nature collects various categories of Personal Information when you use the Back to Nature Website or our services. A more detailed description of the information Back to Nature collects and how we use it is provided above in "Collection of Personal Information" section. The "Sharing Personal Information" section describes the categories of third parties with whom we share Personal Information, and what information may be shared under different circumstances. If you are a resident of Colorado, you have the right to (1) request to know what Personal Information has been collected about you, and to access that information; (2) request to correct inaccuracies in your Personal Information; (3) request deletion of your Personal Information, subject to exceptions; and (4) obtain a copy of your Personal Information. Also, a Colorado consumer may not be discriminated against for exercising the consumer’s Colorado privacy rights. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing complianceamericas@barilla.com.

Connecticut Residents

Connecticut residents have certain rights around Back to Nature's collection, use, and sharing of their Personal Information. Back to Nature sells your Personal Information; however, Back to Nature only "sells" Personal Information in connection with cookies and similar technologies. Back to Nature does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Back to Nature engages in “targeted advertising” as that term is defined in the Connecticut Data Privacy Act ("CTDPA").

Back to Nature collects various categories of Personal Information when you use the Back to Nature Website or our services. A more detailed description of the information Back to Nature collects and how we use it is provided above in the section titled "Collection of Personal Information" section. The "Sharing Personal Information" section describes the categories of third parties with whom we share Personal Information, and what information may be shared under different circumstances. If you are a resident of Connecticut, you have the right to: (1) request to know what Personal Information has been collected about you, and to access that information; (2) request to correct inaccuracies in your Personal Information; (3) request deletion of your Personal Information, subject to exceptions; and (4) obtain a copy of your Personal Information. Also, a Connecticut consumer may not be discriminated against for exercising the consumer’s Connecticut privacy rights. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing complianceamericas@barilla.com.

Virginia Residents

Virginia residents have certain rights around Back to Nature's collection, use, and sharing of their Personal Information. Back to Nature does not sell your Personal Information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, Back to Nature does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Back to Nature may engage in “targeted advertising” as that term is defined in the Virginia Consumer Data Protection Act ("VCDPA").

Back to Nature collects various categories of Personal Information when you use the Back to Nature Website or our services. A more detailed description of the information Back to Nature collects and how we use it is provided above in "Collection of Personal Information" section. The "Sharing Personal Information" section describes the categories of third parties with whom we share Personal Information, and what information may be shared under different circumstances. If you are a resident of Virginia, you have the right to (1) request to know what Personal Information has been collected about you and to access that information; (2) request to correct inaccuracies in your Personal Information; (3) request deletion of your Personal Information, subject to exceptions; and (4) obtain a copy of your Personal Information. Also, a Virginia consumer may not be discriminated against for exercising the consumer’s Virginia privacy rights. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing complianceamericas@barilla.com.