PRIVACY
POLICY
Information we collect
Information you provide to us
We collect the personal information you provide to us when you purchase our products or visit our website. The categories of information we may collect include:
- Personal Identifiers, including name, email address, postal address, and telephone number
- Commercial and Financial Information, including purchases and credit card or debit card number
- Physical and Audio Data, including physical characteristics or descriptions
- Characteristics of Protected Classifications, including age, sex or gender, and gender identity or expression
To the extent we process deidentified personal information, we will make no attempt to reidentify such data.
Information collected automatically
We automatically collect internet or other electronic information about you when you visit our website, such as IP address, browsing history and interactions with our website. This data may be collected using browser cookies and other tracking technologies.
Browser Cookies. We use cookies to create a better experience for you on our site. For example, cookies prevent you from having to login repeatedly, and they help us remember items you've added to your cart. We also use third-party cookies, which are cookies placed by third parties for advertising and analytics purposes. You can control these cookies through your browser settings.
Opt-Out Preference Signals. Your browser settings may allow you to automatically transmit an opt-out preference signal, such as the Global Privacy Control (GPC) signal, to online services you visit. When we detect such signal, we place a U.S. Privacy String setting in your browser so that any third party who respects that signal will not track your activity on our website. Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us. GPC is supported by certain internet browsers or as a browser extension. Find out how to enable GPC..
Information from other sources
We may collect personal information about you from third-party sources, including Other consumers (e.g., referrals).
Other consumers (e.g., referrals)
Personal Identifiers, including Name, Email address, and Telephone number
How long we keep your data
We do not retain data for any longer than is necessary for the purposes described in this Policy.
We generally retain data according to the guidelines below.
| TYPE OF DATA | RETENTION PERIOD |
| Cookies and online data we collect while you use our website, including Online Identifiers, Internet Activity | We delete or anonymize data concerning your use of our website within 10 years of collecting it. |
| Data we collect in order to process and ship orders you place with us, including Name, Email address, Postal address, Telephone number, Purchases, Credit card or debit card number, Physical characteristics or descriptions, Age, Sex or gender, Gender identity or expression | We keep personal information related to products and services you purchase for as long as the personal data is required for us to fulfill our contract with you, and for 10 years from your last purchase with us. We may keep data beyond this period in anonymized form. |
| Data we collect when you contact us for customer support and other inquiries, including Name, Email address, Purchases | We keep customer feedback and correspondence with our customer service for up to 10 years to help us respond to any questions or complaints. We may keep data beyond this period in anonymized form. |
| Data we collect when you sign up for promotional and marketing communications, including Name, Email address, Telephone number | Where you have signed up to receive promotional and marketing communications from us, we will retain any data collected until you opt out or request its deletion. We may keep data beyond this period in anonymized form. We will further retain a record of any opt-outs in order to prevent sending you future communications. |
| Data we collect when you review our products, answer surveys, or send feedback, including Name, Email address | We retain review, survey, and feedback data for up to 10 years following your last contact with us. We may keep data beyond this period in anonymized form to help improve our products and services. |
| Data we collect in connection with privacy requests, including Name, Email address, Online Identifiers | We retain records related to privacy requests for a minimum of 24 months following the completion of the request. |
| Data we collect for security purposes, including Online Identifiers | We retain security-related data as long as necessary to comply with our legal obligations and to maintain and improve our information security measures. |
Purposes of Processing
We process personal information for the following purposes:
- Conducting Surveys
- Creating Customer Profiles
- Data Storage
- Delivering Targeted Ads
- Fulfilling Customer Orders
- Improving our Products & Services
- Internal Business Operations
- Meeting Compliance & Legal Requirements
- Operating our Website or Mobile Apps
- Preventing Fraud
- Processing Payments
- Providing Customer Support
- Sending Promotional Communications
How we disclose information
Information Disclosed for Business or Commercial Purposes in the Last 12 Months, and Categories of Parties Disclosed To
We may disclose the following personal information about you when you purchase our products or visit our website:
| Personal Information Category | Categories of Service Providers | Categories of Third Parties |
| Personal Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Commerce Software Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, Sales & Marketing Tools, and Shipping Services | Ad Networks, Sales & Marketing Tools, and Shipping Services |
| Online Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Commerce Software Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, and Sales & Marketing Tools | Ad Networks and Data Analytics Providers |
California Privacy Notice (CCPA)
This section provides additional information for California residents under the California Consumer Privacy Act (CCPA). The terms used in this section have the same meaning as in the CCPA. This section does not apply to information that is not considered "personal information," such as anonymous, deidentified, or aggregated information, nor does it apply to publicly available information as defined in the CCPA.
To the extent we process deidentified personal information, we will make no attempt to reidentify such data.
Collection and Disclosure of Personal Information
The personal information we collect is described above in Information we collect. The personal information we disclose for business or commercial purposes is described above in How we disclose information. The length of time for which we retain personal information is described above in How long we keep your data. Our purposes for processing data are described above in Purposes of processing.
Information “Sharing” and “Selling”
We “share” certain personal information with third party ad networks for purposes of behavioral advertising, including: Characteristics of Protected Classifications, Commercial and Financial Information, Internet Activity, Online Identifiers, and Personal Identifiers. This allows us to show you ads that are more relevant to you.
We "sell" personal data to third parties, as that term is defined in the CCPA.
You may opt-out of these data practices by emailing hello@sobofoods.com
We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age.
CCPA Rights
Your CCPA rights are described below. Make a privacy request by emailing us at hello@sobofoods.com
Right to Know and Access
You have the right to request to know and access the following about the personal information we have collected about you in the past 12 months:
- the categories and specific pieces of personal information we have collected about you
- the categories of sources from which we collect personal information about you
- the business or commercial purposes for which we collect, sell, or share personal information
- the categories of third parties with whom we disclose the information
- the categories of personal information about you that we have sold, shared, or disclosed for a business purpose, and the categories of third parties to whom we have sold, shared, or disclosed that information for a business purpose
The information we would provide to you in response to a Request to Know Categories is contained in this Privacy Notice. To receive a copy of the specific personal information we have about you, submit a Request to Know or Access via the link above. If you make a Request to Know more than twice in a 12-month period, or we determine the request is manifestly unfounded or excessive, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal information about you that you have provided to us. Subject to certain limitations, we will delete from our records your requested personal information and direct our service providers to do the same.
Right to Non-Discrimination
If you exercise your CCPA consumer rights:
We will not deny goods or services to you
We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties
We will not provide a different level or quality of goods or services to you
We will not suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
We will not retaliate against you, as an employee, applicant for employment, or independent contractor
We may still offer you certain financial incentives permitted by the CCPA such as discounts, rewards, premium features, or loyalty accounts that can result in different prices, rates, or quality levels.
Right to Opt-Out
You have the right to opt-out of any selling and sharing of your personal information.
You may exercise your right to opt-out by emailing hello@sobofoods.com
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.
Request Verification
Before we can respond to a Request to Know or Request to Delete, we will need to verify that you are the consumer who is the subject of the CCPA request. Verification is important for preventing fraudulent requests and identity theft. Requests to Opt-Out do not require verification.
Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your CCPA request. If you submit a request not through our webform, we will ask you to provide the same information requested in the webform.
For a request that seeks specific personal information, we ask that you sign a declaration stating that you are the consumer whose personal information is the subject of the request, as required by the CCPA.
In some cases, we may have no reasonable method by which we can verify a consumer's identity. For example:
If a consumer submits a request but we have not collected any personal information about that consumer, we cannot verify the request.
If the only data we have collected about a consumer is gathered through website cookies (i.e. the consumer visited our website but had no other interaction with us), we are unable to reasonably associate a requester with any data collected; therefore, we cannot verify the request.
Authorized Agent
A California resident's authorized agent may submit a rights request under the CCPA by emailing us at hello@sobofoods.com Requests submitted by an authorized agent will still require verification of the consumer who is the subject of the request in accordance with the process described above. We will also ask for proof that the consumer who is the subject of the request authorized an agent to submit a privacy request on their behalf by either verifying their own identity with us directly or directly confirming with us that they provided the authorized agent permission to submit the request. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 may also submit proof of statutory power of attorney, which does not require separate consumer verification.
If you have trouble accessing this notice, please contact us at hello@sobofoods.com
Contact Us
If you have any privacy-related questions or have trouble accessing this notice, please email hello@sobofoods.com
Virginia Privacy Notice (VCDPA)
This section provides additional information for Virginia residents under the Virginia Consumer Data Protection Act (VCDPA). The terms used in this section have the same meaning as in the VCDPA. This section does not apply to information that is not considered "personal data," such as deidentified or publicly available information as defined in the VCDPA.
Collection and Disclosure of Personal Information
The personal data we collect is described above in Information we collect. The personal data we disclose to third parties and the categories of third parties to whom we disclose personal data is described above in How we disclose information. The length of time for which we retain personal information is described above in How long we keep your data. Our purposes for processing data are described above in Purposes of processing.
Data “Selling” and Targeted Advertising
We process personal data for purposes of targeted advertising (as defined in the VCDPA), including online identifiers and internet activity. This allows us to show you ads that are more relevant to you.
You may opt-out of these data practices by emailing hello@sobofoods.com
We do not receive monetary consideration in exchange for your data and therefore do not "sell" your data as defined in VCDPA.
Profiling
The VCDPA gives consumers the right to opt out of automated profiling that produces legal or similarly significant effects, such as approval for a loan, employment, or insurance.
We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.
VCDPA Rights
Your VCDPA rights are described below. Make a privacy request by emailing hello@sobofoods.com
Right to Access
You have the right to confirm whether we are processing personal data about you and to access such data. Where processing is carried out by automated means, you have a right to receive a copy of your personal data in a portable and readily usable format that allows you to transmit your data to another controller.
If you make an Access Request more than twice in a 12-month period, or we determine the request is manifestly unfounded or excessive, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal data provided by or obtained about you. Subject to certain limitations, we will permanently delete any such personal data from our records and direct our processors to do the same.
Right to Non-Discrimination
If you exercise your VCDPA consumer rights:
We will not deny goods or services to you
We will not charge you different prices or rates for goods or services
We will not provide a different level or quality of goods or services to you
However, we may offer a different price, rate, level, quality, or selection of products or services if your personal data is required in order to provide those products or services and you have exercised your right to opt out, or the offer is related to a voluntary loyalty or rewards program.
Right to Opt-Out
Sale of Personal Data:
We do not sell your personal data, as defined by the VCDPA.
Targeted Advertising:
Exercise your right to opt-out by emailing hello@sobofoods.com.
Profiling:
We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.
Authenticating Your Request
Once we receive your request, we will verify the information you provided by matching the information that we have collected. If we cannot authenticate your request, we may ask for additional information from you. If you are unable to provide additional information, or we are unable to authenticate the request using commercially reasonable efforts, we may deny your request.
Right to Appeal
If we decline to take action in response to any of your privacy requests, you have the right to appeal that decision within a reasonable amount of time, but no later than 90 days from the date of our decision. To submit a request for appeal, email hello@sobofoods.com
If you believe your rights have been violated and you are not able to resolve the issue directly with us, you may file a complaint with the Virginia Attorney General’s Office.
Colorado Privacy Notice (CPA)
This section provides additional information for Colorado residents under the Colorado Privacy Act (CPA). The terms used in this section have the same meaning as in the CPA. This section does not apply to information that is not considered "personal data," such as deidentified or publicly available information as defined in the CPA.
Collection and Disclosure of Personal Information
The personal data we collect is described above in Information we collect. The personal data we disclose to third parties and the categories of third parties to whom we disclose personal data is described above in How we disclose information. The length of time for which we retain personal information is described above in How long we keep your data. Our purposes for processing data are described above in Purposes of processing.
Data “Selling” and Targeted Advertising
We "sell" personal data to third parties, as that term is defined in the CPA.
We process personal data for purposes of targeted advertising (as defined in the CPA), including online identifiers and internet activity. This allows us to show you ads that are more relevant to you.
You may opt-out of these data practices by emailing hello@sobofoods.com
Profiling
The CPA gives consumers the right to opt out of automated profiling that produces legal or similarly significant effects, such as approval for a loan, employment, or insurance.
We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.
CPA Rights
Your CPA rights are described below. Make a Privacy Request by emailing hello@sobofoods.com
Right to Access
You have the right to confirm whether we are processing personal data about you and to access such data. You have a right to receive a copy of your personal data in a portable and readily usable format that allows you to transmit your data to another controller.
If you make a Request to Know more than twice in a 12-month period, or we determine the request is manifestly unfounded or excessive, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal data we have obtained about you. We will permanently delete any such personal data from our records and direct our processors to do the same. However, we may retain your personal data if it is necessary for certain purposes, including the following:
To comply with legal obligations
To comply with an official investigation or cooperate with law-enforcement agencies
To establish or defend legal claims
To complete an obligation to you that you have requested
To respond to security incidents, fraud, harassment, and other similar activity
To identify and repair technical errors
To conduct internal research to develop, improve, and repair our products and services
For internal operations that are reasonably aligned with your expectations
Any personal data retained for these purposes will not be processed for other purposes.
Right to Non-Discrimination
If you exercise your CPA consumer rights:
We will not deny goods or services to you
We will not charge you different prices or rates for goods or services
We will not provide a different level or quality of goods or services to you
However, we may offer a different price, rate, level, quality, or selection of products or services if the exercise of your CPA rights affects the feasibility or the value of those products or services, or the offer is related to a voluntary loyalty or rewards program.
Right to Opt-Out
You have the right to opt-out of any selling of your personal data, processing of your personal data for purposes of targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects for you.
You may exercise your right to opt-out by emailing hello@sobofoods.com
Authorized Agents. You may authorize an agent to submit a Request to Opt-Out on your behalf, including through a technology such as a web link, browser setting, or global device setting. We will comply with such requests if we are able to authenticate your identity and the agent’s authority to act on your behalf.
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.
Authenticating Your Request
Once we receive your request, we will verify the information you provided by matching the information that we have collected. If we cannot authenticate your request, we may ask for additional information from you. If you are unable to provide additional information, or we are unable to authenticate the request using commercially reasonable efforts, we may deny your request.
Right to Appeal
If we decline to take action in response to any of your privacy requests, you have the right to appeal that decision within a reasonable amount of time, but no later than 90 days from the date of our decision. To submit a request for appeal, email hello@sobofoods.com
If you believe your rights have been violated and you are not able to resolve the issue directly with us, you may file a complaint with the Colorado Attorney General’s Office.
Connecticut Privacy Notice (CTDPA)
This section provides additional information for Connecticut residents under the Connecticut Data Privacy Act (CTDPA). The terms used in this section have the same meaning as in the CTDPA. This section does not apply to information that is not considered "personal data," such as deidentified or publicly available information as defined in the CTDPA.
If you have any questions or wish to contact us regarding this privacy notice, please send an email to hello@sobofoods.com
Collection and Disclosure of Personal Information
The personal data we collect is described above in Information we collect. The personal data we disclose to third parties and the categories of third parties to whom we disclose personal data is described above in How we disclose information. The length of time for which we retain personal information is described above in How long we keep your data. Our purposes for processing data are described above in Purposes of processing.
Data “Selling” and Targeted Advertising
We "sell" personal data to third parties, as that term is defined in the CTDPA.
We process personal data for purposes of targeted advertising (as defined in the CTDPA), including online identifiers and internet activity. This allows us to show you ads that are more relevant to you.
You may opt-out of these data practices by emailing hello@sobofoods.com
Profiling
The CTDPA gives consumers the right to opt out of automated profiling that produces legal or similarly significant effects, such as approval for a loan, employment, or insurance.
We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.
CTDPA Rights
Your CTDPA rights are described below. Make a Privacy Request by emailing hello@sobofoods.com
Right to Access
You have the right to confirm whether we are processing personal data about you and to access such data. Where processing is carried out by automated means, you have a right to receive a copy of your personal data in a portable and readily usable format that allows you to transmit your data to another controller.
If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal data provided by or obtained about you. We will permanently delete any such personal data from our records and direct our processors to do the same. However, we may retain your personal data if it is necessary for certain purposes, including the following:
To comply with legal obligations
To comply with an official investigation or cooperate with law-enforcement agencies
To establish or defend legal claims
To complete an obligation to you that you have requested
To respond to security incidents, fraud, harassment, and other similar activity
To identify and repair technical errors
To conduct internal research to develop, improve, and repair our products and services
For internal operations that are reasonably aligned with your expectations
Any personal data retained for these purposes will not be processed for other purposes.
Right to Non-Discrimination
If you exercise your CTDPA consumer rights:
We will not deny goods or services to you
We will not charge you different prices or rates for goods or services
We will not provide a different level or quality of goods or services to you
However, we may offer a different price, rate, level, quality, or selection of products or services if your personal data is required in order to provide those products or services and you have exercised your right to opt out, or the offer is related to a voluntary loyalty or rewards program.
Right to Opt-Out
You have the right to opt-out of any selling of your personal data, processing of your personal data for purposes of targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects for you.
You may exercise your right to opt-out by emailing hello@sobofoods.com
Authorized Agents. You may authorize an agent to submit a Request to Opt-Out on your behalf, including through a technology such as a web link, browser setting, or global device setting. We will comply with such requests if we are able to authenticate your identity and the agent’s authority to act on your behalf.
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.
Authenticating Your Request
Once we receive your request, we will verify the information you provided by matching the information that we have collected. If we cannot authenticate your request, we may ask for additional information from you. If you are unable to provide additional information, or we are unable to authenticate the request using commercially reasonable efforts, we may deny your request. Authentication is not required for a Request to Opt-Out, but we may deny the request if we have a good faith, reasonable, and documented belief that the request is fraudulent.
Right to Appeal
If we decline to take action in response to any of your privacy requests, you have the right to appeal that decision within a reasonable amount of time, but no later than 90 days from the date of our decision. To submit a request for appeal, email hello@sobofoods.com
If you believe your rights have been violated and you are not able to resolve the issue directly with us, you may file a complaint with the Connecticut Attorney General’s Office.
Notice of Financial Incentive
Consumers who sign up for our marketing SMS texts may receive a discount on their first purchase. To opt in, a consumer must enter their phone number into the form and consent to receive emails in exchange for a discount provided via coupon code. A consumer may unsubscribe from our marketing emails by using the unsubscribe link in the email footer/replying STOP via text at any time. We calculate the value of the offer and financial incentive by using the expense related to the offer.
