Consumer Privacy Policy

Effective Date: January 1, 2025

This Consumer Privacy Policy (this “Policy”) describes how Lactalis American Group, Inc. and its subsidiaries and affiliates (collectively referred to as “Lactalis,” “us,” “we,” or “our”) collects, uses, stores, and discloses personal information when you as a consumer (rather than a business partner or job applicant) (1) use or access our U.S. websites, including lactalisamericangroup.com; galbanicheese.com; presidentcheese.com; parmalatmilk.com; valbresocheese.com; scottishcheddarcheese.com; up2u.co; hoffmanscheese.com; blackdiamondcheese.com; societeroquefort.com; leerdammer.us; pronativ.com; lactalisculinary.com, and ambrosifoodusa.com (collectively referred to as the “Sites” or individually referred to as a “Site”), (2) tour our U.S. facilities; or (3) when you call or email us with questions, submissions, or complaints (items (1) through (3) are collectively referred to herein as “the Services” or “our Services”).  It also covers how we use data collected about you that we receive from social media platforms when you visit our pages on Facebook, Instagram, and other platforms (“Lactalis Social Media Pages”).

If you do not agree to how Lactalis collects, uses, and discloses personal information as described in this Policy, please discontinue use of the Services.  This Policy is incorporated into our Terms of Use

WHAT THIS POLICY COVERS. This Policy applies to the personal information Lactalis obtains in various contexts, both online and offline, from you and from third parties, including when you access or use our Sites or Services; you purchase our products through Service Providers on our Sites; you participate in any sweepstakes we administer; communicate with us; engage with us on social media; or participate in any of our promotional events, such as sweepstakes.

We may provide different or additional privacy notices in connection with certain activities, programs, and offerings. We may also provide additional “just-in-time” notices that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal information.

WHAT THIS POLICY DOES NOT COVER. This Policy does not cover the personal information that is collected by the social media platforms that host our social pages or by our Service Providers that fulfill orders places on our Sites but is not shared with us. Please read those platform privacy policies. This Policy does not cover personal information of employees, job applicants, or individuals who interact with Lactalis in their capacity as an employee or independent contractor of Lactalis suppliers, retailers or distributors of Lactalis products (“B2B Information”).  For more information regarding our privacy practices as it relates to B2B Information, please review our B2B Privacy Policy.

Our Sites may include links to websites and/or applications operated and maintained by third parties. Please note that we have no control over the privacy practices of websites or applications that we do not own. We encourage you to review the privacy practices of those third parties.

TWO TYPES OF INFORMATION WE COLLECT WHEN YOU VISIT OUR SITES

There are two types of Information that may be collected through our Sites: (1) “Personal Information,” which is information that identifies, relates to, describes, or can be associated with you or, if you are a California resident, a household; (2) “Usage Data,” which is information related to your use of the Sites, including information about the computer and mobile device you use when visiting the Sites, as well as data regarding your activity, such as the actions you take while browsing our Sites, the browser and/or device you use, and the date and time of your use of the Sites. Most of the Personal Information we collect we receive when you voluntarily share it with us. Most of the Usage Data is not Personal Information and is not stored by us. Instead, it is stored on cookies placed on your browser and read by third parties, as explained in more detail below.

SUMMARY CHART

The chart below summarizes the information we collect, information sources, the purposes for collection and use, and the categories of recipients we share with.

Category of Personal Information Collected	Source	Purpose of Collection	Categories of Recipients
Identifiers and other “Personal Information” described in 1798.80(e) of the California Civil Code): Your full name, postal address, e-mail address, phone number, social media handle, device identifier, internet protocol (IP) address or ad identifier “Other Examples” of this category: your signature, Social Security Number, physical characteristics or description, driver’s license or state identification card number, passport number, bank account number, insurance policy number, education, employment, employment history, credit card number, debit card number, or any other financial information, medical information, or health insurance information	You, when you contact us by phone or email; register for or participate in a sweepstake; or sign up to receive messages from us You, when you purchase our products through Service Providers on our Sites We may receive your social media handle from social media platforms when you visit our pages on those platforms, and other information you may post there We collect your IP address and mobile device identifiers automatically when you visit our Sites We will receive your name and contact information if our business partners forward your complaint to us We do not collect Other Examples of Personal Information	To communicate with you regarding our products and promotions. This includes responding to complaints and administering sweepstakes Our servers need your IP address and mobile device ID to respond to your request for pages of our Sites. We do not store your IP address with your other Personal Information	Corporate Affiliates Service Providers, subject to their agreement to not use Personal Information for any purpose other than performing services for us
Protected classification characteristics under California or federal law, namely, 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)	We do not collect any information in this category
Commercial information, such as products you have purchased from our retailers or through Service Providers on our Sites	From our retailers and third-party Service Providers From you, if you tell us in an email or phone call	To understand our customers’ preferences To fulfill an order you place through our Sites To address your complaints or questions about products you purchase through our Sites	Service Providers
Biometric information	We do not collect any information in this category
Browsing information: By IP address: landing pages, browsing activity, content or ads (about our Website) viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Website, the websites you visit after our Website; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information	You, through your device, by using our Sites Service Providers Advertising providers that we hire to advertise our products and Sites online Cookies and tracking technologies	Personalizing your experience on our Sites Marketing and advertising our products, specifically, understanding which of our marketing campaigns resulted in your visit to our Sites We use IP address to understand the general geographic location of our customer base Third parties may use cookies to track your browsing history on our Sites so that they can show you targeted ads for third party products on other websites	Service Providers Third parties relating to legal requests, if required by law or if we believe in good faith that it is reasonably necessary Third parties who buy all or part of our business or assets
Geolocation data	We can infer your general location by your IP address You may provide your city or zip code to use when you use our “where to buy” or “product locator” features, as applicable	To provide you with relevant information about retail stores that sell our products	Our website Service Providers
Payment information: name, card issuer and card type, credit or debit card number, expiration date, CVV code, and billing address	You, when you purchase our products through Service Providers on our Sites We do not receive payment card information from retailers or Service Providers
Professional or employment-related information	We do not collect any information in this category
Audio and video information, such as video images and recorded phone calls	You, when you call with complaints or questions, or when you send us audio and/or visual information via email. Our facilities, when you take a tour	We record customer service calls for quality assurance and training purposes We also use Closed Circuit Television or CCTV in our facilities for safety, security, fraud, loss prevention, and operational purposes	Our training Service Providers Law enforcement in the event of a security issue
Online chats	We maintain a transcript of chats We receive the transcripts from a chat Service Provider	For quality assurance and training purposes	Our training Service Providers Law enforcement in the event of a security issue

DETAILS ABOUT HOW WE COLLECT YOUR PERSONAL INFORMATION.

• Automatically by Using Online Tracking and Data Collection Technologies: When you visit our websites, open or click on emails we send you, or interact with our advertisements, we or third parties we work with (such as Google Analytics) automatically collect certain information using online tracking technologies. This may include the URL of the page you’re visiting and your IP address, from which we may infer the city and state you are accessing the Internet from. For more information, please see Cookies and Similar Online Tracking Technologies section below.
• Social Media Platforms and Networks: If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (including Meta/Instagram/Facebook, TikTok, Twitter/X, Google, YouTube, and Pinterest) in connection with our Sites, we collect information that you disclose to us, or that the social media platforms disclose to us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.
• Other Sources: We may obtain information about you from other sources, such as data analytics providers, e-commerce, marketing, or advertising Service Providers, fraud prevention Service Providers, vendors that provide services on our behalf, or publicly available sources. We also create information based on our analysis of the information we have collected from you.
• Parties to corporate transactions. As permitted by law, we may receive personal information 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 a business or assets.

DETAILS ABOUT HOW WE USE YOUR PERSONAL INFORMATION.

• Analytics and Personalization: We may use personal information to conduct research and analytics, including to improve our product offerings; to understand how you interact with our Sites, advertisements, and communications with you; to improve the Sites and marketing campaigns; to customize the marketing and advertising that we show you; to understand how you use our Sites; and to better understand our customers’ needs.
• Security and Fraud Prevention: We may use personal information to fulfill a product order made through Service Providers on our Sites, to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity; attempts to manipulate or violate our policies, procedures, and terms and conditions; and security incidents.
• Legal Obligations: We may use personal information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.

DETAILS ABOUT HOW WE DISCLOSE YOUR PERSONAL INFORMATION.

• Affiliates: We may disclose personal information with our Corporate Affiliates, including our parent company, sister companies, and subsidiaries. Such Corporate Affiliates process personal information on our behalf as our Service Providers.
• Service Providers: We may disclose certain personal information to Service Providers that perform services to support our business functions and internal operations including: sending postal mail, e-mails, and text messages; analyzing customer data; providing marketing assistance; fulfilling a product order placed on our Sites; administering our sweepstakes; investigating fraudulent activity; and providing customer service.
• Social Media Platforms, Networks, and E-Commerce Service Providers: Some of our Sites may have features such as, plugins, widgets, e-commerce shop integrations, and/or other tools made available by social media platforms and networks that may result in information being collected or disclosed between us and such parties. Their use of your information is not governed by this Policy.
• Legal Process: We may disclose personal information in response to subpoenas, warrants, court orders, government inquiries, or investigations; or to comply with relevant laws and regulations. We may also disclose information to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.
• Merger or Acquisition: We may disclose your personal information in connection with certain corporate events such as a potential merger, sale of company assets, financing, insolvency or acquisition of all or a portion of our business to another company.
• Deidentified Personal Information: We may deidentify your personal information and disclose this deidentified information to others as permitted by applicable law. Where we deidentify information or use deidentified information, we will use the information only in deidentified form and will not attempt to reidentify that information.

COOKIES AND SIMILAR ONLINE TRACKING TECHNOLOGIES (USAGE DATA). We and our third–party partners and Service Providers (such as advertising and analytics providers) use pixels, web beacons, cookies, and other similar online tracking technologies (collectively, “online tracking technologies”) to gather information when you interact with the Sites and our email communications. Some Sites may not use all the types of cookies below.

• Strictly Necessary: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will not then work. These cookies do not store any personally identifiable information.
• Functional: Some online tracking technologies help us maintain the security of the Sites, prevent crashes, fix bugs, save your preferences, and assist with basic website functions. These cookies are “functional.”
• Performance: We also permit Service Providers to use online tracking technologies on the Sites for analytics, to measure the performance of our advertising and of our Sites. These cookies are “performance” or “analytics.”
• Targeting: We permit third parties and Service Providers to use your browsing behavior on our Sites to build a profile of your interests, so that they can show you tailored advertisements on other websites about other companies’ products. These are called “targeting” cookies. This is called “online behavioral advertising” or “OBA.” When we allow OBA cookies to be placed on your browsers when you visit our Sites, the laws of some states deem this a “sale” or “sharing” of your personal information.
• Opting Out: Please see our Cookie Management Policy (https://lactalisamericangroup.com/cookie-management-policy/) for more information about how we use cookies on the Sites, and how you may opt out of the placement of functional, performance, and/or targeting cookies on your browser.

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION. Your personal information will be saved only for as long as it is needed for the purposes it was collected. Your personal information may also be stored for a longer period if required by applicable legal retention periods.

In some circumstances we may de-identify your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

HOW WE PROTECT YOUR PERSONAL INFORMATION. Personal information is maintained on cloud servers, and is accessible by authorized employees, representatives, and agents as necessary for the purposes described in this Policy. Note: IP addresses are not accessible to the groups defined in the previous sentence. We maintain reasonable and appropriate physical, electronic, and procedural safeguards designed to help protect your personal information. While we attempt to protect your personal information in our possession, no method of transmission over the Internet or security system is perfect, and we cannot promise that information about you will remain secure in all circumstances.

YOUR PRIVACY CHOICES AND RIGHTS UNDER STATE LAW. Depending on where you live (including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, New Jersey, Nebraska, New Hampshire, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia), you may have certain rights with respect to your personal information, as described below. Please note that the exercise of these rights may be restricted by the applicable law of your residency and exemptions permitted under relevant laws.  In some cases, we may lawfully refuse your request, such as where we are legally obligated.

• Right to Opt Out of the “Sale” or “Sharing” of your Personal Information (Your Browsing History) for Targeted Advertising. There are three ways you can opt out: (1) By broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. We will honor such opt-out preference signals. (2) Opting out of Targeting Cookies in our consent management tool, as described at https://lactalisamericangroup.com/cookie-management-policy/. (3) Clicking on the Do Not Sell My Personal Information in the banner that appears when you first visit one of our Sites.
• The Right to Opt Out of Profiling. You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not engage in such profiling and therefore do not provide a mechanism for you to exercise this right.
• The Right to Limit the Use of Sensitive Personal Information (also known as Protected Classification Characteristics). You may have the right to limit the use of sensitive personal information. We do not collect sensitive personal information through the Sites or the Services and therefore do not provide a mechanism for you to exercise this right.
• The Right to Access/Data Portability. Subject to certain exceptions, you may have the right to request a copy of the personal information that we collected about you and receive it in a portable and machine-readable format. In Minnesota, Oregon, and Rhode Island, you have the right to know the list of the third parties to whom we have disclosed your personal information.
• The Right to Correction. You may have the right to correct, rectify, or update inaccurate personal information that we hold about you.
• The Right to Deletion: You may have the right to delete your personal information provided by or obtained about you. Please note that there are exceptions where we do not have to fulfill a request to delete information, such as when the deletion of information would create problems with compliance with a legal obligation.
• Right to Not Be Discriminated Against for Exercising Your Rights You have the right not to be discriminated against (e.g., not offering you goods/services or different pricing) for exercising any of the rights afforded to you by applicable law.
• Right to Appeal. You may have the right to appeal our decision with respect to exercising any of the rights afforded to you by law. To do so, please contact us emailing us at UBA-Privacy_Policy@us.lactalis.com with the words “Appeal My Privacy Decision” in the subject line. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.
• Right to Withdraw Consent: Where required by law we have obtained your consent to collect, use, disclose, or otherwise process your personal information, you have the right to withdraw that consent. If you withdraw consent, we may not be able to provide certain services to you.

How to Submit a Request: You may submit a request to exercise your privacy rights through our online form available here (from the “How Can We Help You?” dropdown, please select “Something else” and in the “Message” field state that you would like to exercise your privacy rights) or email us at UBA-Privacy_Policy@us.lactalis.com, with the words “Exercise My Privacy Rights” in the subject line.  In the request, please specify which right you are seeking to exercise and the scope of the request.  We will confirm receipt of your request within 10 days.  We may require specific information from you to help us verify your identity and process your request.  If we are unable to verify your identity, we may deny your request. Identity Verification.Only you, or an authorized agent may make a verifiable consumer request related to your personal information. The verifiable consumer request must: 1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person; and 2) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request to exercise your access, portability, correction and/or deletion rights 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.

Authorized Agent. You may designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.  If you have been designated as an authorized agent to submit a request on behalf of another customer, you must indicate so when you submit the request.

Complaints We commit to resolve complaints about your privacy and our collection or use of your personal information. We ask that you submit your inquiries or complaints to UBA-Privacy_Policy@us.lactalis.com.

MANAGING COMMUNICATION PREFERENCES

• Email: You can stop receiving promotional emails at any time by clicking on the “unsubscribe” link at the bottom of any promotional email that you receive from us.
• Postal Mail: You can stop receiving promotional mail at any time by emailing us at UBA-Privacy_Policy@us.lactalis.com.
• Text Messages: You can opt-out of receiving text messages from us by replying “STOP” to the text message you receive from us. Please note that this will only opt you out of the specific text messaging program associated with that number.

INTERNATIONAL TRANSFERS. We are based in the United States, and we have Corporate Affiliates and Service Providers that may be located in other countries. If you are accessing the Services from outside of the United States, please be aware that information collected through the Services may be transferred to, processed, stored, and used in the United States and other countries where privacy laws may be less stringent than the laws in your country. Your use of the Services or provision of any information to us therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the United States and other jurisdictions as set out in this Privacy Policy.

CHILDREN’S PRIVACY. We do not intend for our Services to be used by anyone under the age of 18.  We do not knowingly collect, sell, or share personal information of individuals under the age of 18.  If you are a parent or guardian and believe we may have collected information about your child, please contact us immediately by emailing us at UBA-Privacy_Policy@us.lactalis.com.

CHANGES TO THIS POLICY. We reserve the right to amend this Policy at our discretion and at any time.  When we post changes to this Policy, we will change the “Effective Date” at the top.  If we make material changes to this Policy, we will provide notice or obtain consent regarding such changes as may be required by law.

CONTACT US. If you have any questions or concerns regarding this Policy, please feel free to contact us at the following email, telephone number, or mailing address. We would be happy to answer your questions or hear your concerns.

Lactalis American Group
2376 South Park Avenue
Buffalo, NY 14220
Attention: Consumer Relations
Telephone: 1-877-522-8254
Email: UBA-Privacy_Policy@us.lactalis.com.
9 a.m. – 5 p.m. Eastern Time, Monday through Friday, excluding holidays.

CALIFORNIA DISCLOSURES. California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of this Policy.

SHINE THE LIGHT California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you would like to request more information under the California Shine the Light law, and if you are a California resident, you can email us at UBA-Privacy_Policy@us.lactalis.com. Please include “California Shine the Light Request” in the subject line and in the body of your message. Please note that “Shine the Light” rights and CPRA rights described above at YOUR PRIVACY CHOICES AND RIGHTS UNDER STATE LAW are granted by different laws and must be exercised separately.