Date Last Updated: September 18, 2020
This policy applies to information we collect:
- On our Website.
- In email, text, and other electronic messages between you and TreeHouse.
It does not apply to information collected by any other website operated by any third party.
Information Gathered on the Website
TreeHouse collects different types of information about you, including information that can identify, relate to, describe, be associated with, or be reasonably capable of being associated with a consumer or household (“Personal Information”), information that is about you but individually does not personally identify you, and information that we combine with our other users. For purposes of this Policy, the Personal Information that TreeHouse collects about you includes your name, postal address, e-mail address, and telephone number.
Additionally, TreeHouse collects various other categories of data about you, either directly from you or automatically when you visit the website. Some of this data can be attributed to you, which makes it Personal Information. However, some of this data cannot be attributed to you by TreeHouse. This data is not Personal Information.
The additional categories of Personal Information collected include: The products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; and inferences drawn from other Personal Information. For example, information about your purchase preferences.
We also automatically collect data such as: the detail about your visits to our Website, specifically traffic data, location data, logs, and other communication data and the resources that you access and use on the Website; and information about your computer and internet connection, specifically your IP address, operating system, and browser type.
The information we automatically collect is used to estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our Website according to your individual interests; speed up your searches; and recognize you when you return to our Website.
Data we collect automatically which may not be Personal Information, is treated as Personal Information when it is attached to other Personal Information.
Use and Disclosure of Information
The information TreeHouse collects is used to internally improve the content of our Website, notify our visitors of updates, respond to visitor inquiries, process requests for information, notify you of products, special offers and other information about TreeHouse and our affiliates and partners that may be of interest to you, for statistical purposes, for improving the Website or our products and services, to maintain the Website, and for security purposes. We may also use the information we collect from and about you as otherwise described to you at the point of data collection.
Except as provided below, we do not sell, trade or rent your personally identifiable information collected on the Website to others. TreeHouse may disclose personally identifiable information as follows: (a) to our subsidiaries and affiliates; (b) to our third party service providers, vendors, and consultants providing services on our behalf to the extent necessary in order to provide services on our behalf (for example, parties that support our Website); (c) in order to enhance your experience on our Website; (d) if we believe that there has been a violation of our Terms and Conditions, any of our intellectual property or other rights of any third party; (e) in order to respond to a subpoena, court order or other such request; (f) in response to a law enforcement agency’s request or as otherwise required by law; and (g) as otherwise described to you at the point of collection.
Interest Based Advertising
You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. (http://www.networkadvertising.org/choices/) and (http://www.aboutads.info/choices/).
Other websites where you see our ads, such as Facebook, may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some internet browsers, websites (such as Facebook), and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser and/or your device settings for additional information.
Do Not Track
There is currently no common industry or legal standard for interpreting Do Not Track (“DNT”) signals sent from browsers. Therefore, our Website currently does not recognize if your browser sends a DNT signal or similar mechanism to indicate you do not wish to be tracked across websites.
Please be aware that the Website may contain links to other sites on the Internet that are owned and operated by third parties. This includes links to our third-party service provider that operates and manages the Careers portion of our Website. TreeHouse is not responsible for the privacy policies of third party websites to which it links. If you provide any information to such third parties, different rules regarding the collection and use of your Personal Information may apply. We strongly suggest you review such third parties’ privacy policies before providing any data to them. We cannot control this collection of information. You should contact these entities directly if you have any questions about their use of the information that they collect.
TreeHouse takes appropriate steps to ensure data privacy and security including through various hardware and software methodologies, and appropriate means among which access protection by passwords from each device (also in accordance with U.S. Sarbanes-Oxley Act 2002 requirements). However, TreeHouse cannot guarantee the security of any information that is disclosed online. There is no guarantee that information may not be accessed, disclosed, altered or destroyed by a breach of any of our physical, technical, or managerial security measures. Please note that emails and other communications you send to us through our Website are not encrypted, and we strongly advise you not to communicate any confidential information through these means.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Processing of Personal Information in the United States
If you are a resident of the European Economic Area (“EEA”), in order to provide our Websites, products, and services to you, we send and store your Personal Information outside of the EEA, including to the United States. Accordingly, your Personal Information may be transferred outside the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Information.
Your Privacy Rights In California
This California Privacy Notice (“California Notice”) applies to California residents whose Personal Information is processed by TreeHouse pursuant to the California Consumer Privacy Act (“CCPA”) or other California privacy laws described below. The California Notice describes how we protect the Personal Information we process and control relating to California residents and rights California residents may have in relation to this Personal Information. For purposes of this California Notice, “Personal Information” has the meaning provided by the CCPA and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with you, or that is excluded from the CCPA’s scope.
Your California Rights and Choices: As a California resident, you may be able to request to exercise the following rights:
- The Right to Know any or all of the following information relating to your Personal Information we have collected and disclosed in the last 12 months, upon verification of your identity:
- The specific pieces of Personal Information we have collected about you;
- The categories of Personal Information we have collected about you;
- The categories of sources of the Personal Information;
- The categories of Personal Information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of Personal Information we have sold and the categories of third parties to whom the information was sold; and
- The business or commercial purposes for collecting or selling the Personal Information.
- The Right to Request Deletion of Personal Information we have collected from you.
However, this right is limited by a number of exceptions. Fundamentally, if TreeHouse has a permissible need to retain Personal Information, we are not under an obligation to delete such information, even when requested. Generally, we retain Personal Information so we may complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with TreeHouse; comply with a legal obligation; or otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information. As such, we generally do not accept requests to delete Personal Information.
- The Right to Opt Out of Personal Information Sales to third parties now or in the future.
What We Do: While we collect, process, and share your information for purposes described in this policy, which include “business purposes” under the CCPA; we do not currently “sell” Personal Information as most people would typically understand that term. However, we do allow certain third-party advertising partners to collect information about the users of our Website for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting. This activity can be considered a “sale” under California law.
You have the right to opt out of the “sale” of your Personal Information. Such requests may be submitted by following the “Do Not Sell My Personal Information” link at the bottom of the page, or in the settings menu in the App. You may also exercise your rights using the mechanisms described in the Interest Based Advertising section of this Policy above.
You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process Personal Information, for example, if you submit a deletion request, we may no longer be able to provide you our products and services or engage with you in the same manner.
To submit your California Consumer Rights Requests: You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional Personal Information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.
To exercise your California Consumer Rights to Know, Delete, or Opt-Out of Sale, or for additional information, please submit a request to 800-236-1119. You may also exercise your right to Opt-Out of Sale using the mechanisms described in the Interest Based Advertising section of this Policy above.
Finally, you may also submit a verifiable consumer request through an authorized agent. To do so please be prepared for your agent to provide a signed permission to do so, to verify their own identity with us, and to directly confirm with us that you provided the agent permission to submit the request.
California’s “Shine the Light” Law. California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of Personal Information to third parties for their direct marketing purposes. To opt-out of having your Personal Information disclosed to third parties for their direct marketing purposes, please submit a request using one of the California consumer rights request methods designated above.
Data Retention Periods
TreeHouse may retain your Personal Information:
- for as long as necessary to comply with any legal requirement;
- on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
- for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies;
- in order to use Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information. and
- for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.
TreeHouse may also retain information related to any requests to exercise privacy rights for as long as needed or is permitted in light of the purpose(s) for which it was obtained.
Questions and How to Contact Us
TreeHouse Foods, Inc.
2021 Spring Road, Suite 600
Oak Brook, IL 60523 USA
Attention: Law Department