GOODER FOODS, INC. PRIVACY POLICY Last updated: October 24, 2022 First posted: November 16, 2021

This Privacy Policy describes how Gooder Foods, Inc. (“Gooder Foods,” “the Company,” “we,” “us” and “our”) collects, uses, discloses and stores information you provide to us through the Gooder Foods websites, including https://goodles.com (the “Site(s)”), and through other interactions with us such as email, text message, and phone communications, as well as the purchase of Gooder Foods products including but not limited to the sale of GoodlesTM mac and cheese and other noodle-based products (collectively, the “Services”).

This Privacy Policy describes: Information that we collect when you interact with the Services How we use and process the information that we collect How we may share information with third parties The security of your information

1. User Consent. 

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY.  When you submit information to or through the Services, you consent to the collection and processing of your information as described in this Privacy Policy. By using the Services, you accept the terms of this Privacy Policy, our Terms of Use and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, YOU ARE NOT AUTHORIZED TO USE THE SERVICES. 2. Links to Other Sites.   The Services may contain links and widgets related to third-party websites and services, such as social networks (a “Third Party Service”), with which we have no affiliation. A link to or other availability of any Third Party Service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a Third Party Service, you are subject to the privacy policy and practices of the third party that operates the Third Party Service and not this Privacy Policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit. 3. Information We Collect.  “Personal Information” generally means any information that can be used alone or in combination with other information to identify you as an individual, and any other information we associate with it. We collect categories of information, from different sources. We may collect the following Personal Information: a. Profile information and other content you voluntarily provide us, which may include: Contact information when you register on our Site or make a purchase, such as your name, street address, phone number, and/or email address; or when you provide your email address or other contact information to receive marketing communications from us about our products. Any content or contributions you post in a public space on the Site. This includes reviews, comments, videos and photos that you might submit. If you contact us through a social media site, we may collect your social media identifier. Any information you provide in communications with us, such as via social media, email, text message, or our customer call center. Transaction history, for instance if you make a purchase from our online store. Payment information, such as when you make a purchase with us and we need your billing information to process the transaction. If you sign-up for a subscription, our third-party payment processor will maintain your payment card information on file to process your future transactions. In addition, with your consent, our third-party payment processor saves your payment card information for secure 1-click checkout. b. Information that is passively collected when you use the Site, such as by third party analytics tools we use: We may record certain information about visitors to our Site, including the web request, Internet Protocol (“IP”) address, device and mobile ad identifiers, browser information, interaction with the Site, pages viewed, and other such information; we may collect similar information from emails you receive from us that can help us track which emails are opened and which links are clicked by recipients. We use certain cookies, pixel tags and other technologies to help us understand how you use the Site and enable us to personalize your experience on the Sites. To learn more about our use of cookies, please see Section 4, Cookies and Other Information Collection Tools, below. We may ask advertisers or other third-party partners to serve ads or services to your devices, which rely on cookies or similar technologies placed on our Site. With your consent, we may detect the physical location of your device by, for example, general location information shared by your device’s IP address. We collect this information for purposes of providing you with information about promotions or new products that may be relevant to you. We may use your device’s IP address to better understand how our Site and other services and functionality are being used. Should you wish to opt out of the collection of this information, please adjust the settings of your device or web browser so that information about your physical location is not sent to us by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please consult your device settings for further information. c. Where permitted by applicable law, we may receive information from third parties such as advertising and marketing partners, public databases, and social media platforms, to supplement the information we receive from our consumers. If we do so, this policy governs how we can use that information. d. In addition to collecting Personal Information, we may collect information that does not identify you and is not associated with your Personal Information. We may also de-identify or anonymize information so it no longer identifies you. We can aggregate and use such information (“Aggregated Data”) to engage in marketing and other activities in a manner that is privacy sensitive since it does not include Personal Information. Aggregated Data may be derived from Personal Information, but is not considered Personal Information under the law if it cannot be used alone or in combination with other information to directly or indirectly reveal a person’s identity.
4. Cookies and Other Tracking Technologies. What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website again, the cookie allows that site or online service to recognize your browser. Cookies may store unique identifiers, user preferences and other information. Why do we use them? Cookies help us improve the Services by providing us with information about which parts of the Services are most popular, enabling us to analyze technical and navigational information about the Services, and helping us to detect and prevent fraud. We also use cookies and other data collection tools (such as web beacons and server logs) to help improve your experience with the Services. For example, we use Google Analytics to help us measure traffic and analyze how users use the Services (such as the pages most read, time spent, search terms and other engagement data), and to understand more about the demographics of our users and evaluate and improve the user experience and the Sites. These tools use cookies to collect standard internet log information and visitor behavior information. To learn how to turn off cookies, please see Section 8, Choices with Your Personal Information and Opting Out, below. a. Important Notes About your Opt-Out: If you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us across the Internet, but the ads may be less relevant to you and your interests. Interest-based advertising opt-outs work by saving cookies in your browser that tell the various ad partners that you have opted-out. Because cookies are generally browser-specific, your choice will only apply to the web browser from which you opt-out. You must opt-out from each web browser from which you do not want interest-based advertising (and this may involve different devices, if you use more than one). If you delete or clear your browser’s cookies, you will need to opt-out again. 5. How Information is Used. We may use the information we collect for purposes that include: to provide the Services to you, including processing transactions and sending related communications;  to operate, improve, and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us; for customer service, security, to detect fraud or illegal activities and for archival and backup purposes in connection with the provision of the Services; for research and analysis purposes, such as determining trends in consumption of our products and determining where our products may be in demand; to communicate with users where permitted by applicable law; to permit you to participate in social sharing, including social media feeds; to fulfill your requests, such as those relating to ordering and payments; to comply with applicable law and legal process; purposes we disclose to you at the time we collect the information; and to enforce our Terms of Use or other applicable policies. 6. Sharing of Information.   We may share or disclose information as described at the time information is collected or as follows: With Third Party Service Providers Performing Services on Our Behalf.  We share information, including personal information, with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Services, provide data analysis and research services, send out email updates about the Services, provide marketing, analytics and advertising services for us, remove repetitive information from our user lists, and to help us deliver our products and services to customers and process payments. For Legal Purposes.  We and our U.S. service providers also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions in accordance with applicable privacy laws. We and our service providers will disclose personal information as we deem necessary to respond to a subpoena, warrant, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. We may also share personal information as required to pursue available remedies or limit damages we may sustain. Corporate Changes.  We may transfer information, including your personal information, in connection with a proposed or completed merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part). 7. Security and Retention of Your Information.   We employ reasonable security measures designed to protect the security of personal information submitted through the Services. However, the security of personal information transmitted through the Internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our Services. In order to protect us, you and your data, we may suspend your use of the Services, without notice if any breach of security is suspected. Access to and use of password protected and/or secure areas of the Services are restricted to authorized users only. Unauthorized access to such areas is prohibited. 8. Choices with Your Personal Information and Opting Out.
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information: Cookies and Other Tracking Technologies. Web browsers typically allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Mobile devices may also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Services. Google Analytics. If you would like to opt-out from the processing of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on designed for this purpose at https://tools.google.com/dlpage/gaoptout. Email and Text Message Marketing Communications. If you do not wish to receive marketing or promotion messages from us, you can opt out by following the instructions using the “Unsubscribe” link on any email you receive from us or by replying STOP to any text message. If you opt out of receiving such communications, note that we may continue to send you non-promotional transactional or informational emails (such as order confirmation emails or emails about changes to our legal terms). Please note that making such requests does not ensure complete or comprehensive removal of your content. For example, we may retain the information for our own internal records in accordance with the terms of this Privacy Policy. We need to collect personal information to provide certain services. In some cases, if you choose not to provide the information requested, we may not be able to provide you with those services. 9. Effective Date and Changes to Privacy Policy.   The Effective Date of this Privacy Policy is set forth at the top of this webpage. We may change this Privacy Policy from time to time in our discretion. Changes will be posted to this webpage. We encourage you to return to this webpage frequently so that you are aware of our current privacy practices. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions. 10. Non-U.S. Visitors.   All personal information we collect through the Services is currently processed in the United States by us or by a service provider acting on our behalf. When you provide personal information to us through the Services, your personal information will be transferred to and processed in the United States. The Services are currently hosted in the United States. 11. Children.  We do not knowingly collect or maintain personal information from any person under the age of thirteen. No parts of our Services are directed to or designed to attract anyone under the age of thirteen. 12. Your California Privacy Rights.   To learn more about California residents’ rights under the California Consumer Privacy Act, please see the PRIVACY NOTICE FOR CALIFORNIA RESIDENTS, below. 13. Do Not Track.   The Services do not support Do Not Track with respect to the Services at this time. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit www.donottrack.us. 14. Access and Correction.   You may access and change or correct the personal information you provide to us to receive marketing or other communications from us by logging into your Account and adjusting your information within your profile. You may also request access to or correction of other personal information in our records (subject to limitations under applicable law) by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to personal information records. Where no overriding legal basis or legitimate reason continues to exist for processing personal information, you may request that we delete your personal information. We will take all reasonable steps to ensure erasure. 15. Notices.   Please send all questions, comments and notices regarding this Privacy Policy to our Privacy Leader at privacy@goodles.com. 16. Contact Us If you have any questions or concerns about Gooder Foods’ privacy policy and practices (or the privacy practices of our service providers), or would like to lodge a complaint, please contact our Privacy Leader at privacy@goodles.com.

CALIFORNIA CONSUMER PRIVACY ACT:  PRIVACY NOTICE FOR CALIFORNIA RESIDENTS Effective Date: November 16, 2021 This California Privacy Policy describes Gooder Foods, Inc.’s (“Gooder Foods,” “we,” “us,” or “our”) practices regarding the collection, use, and disclosure of the personal information of California residents (“Consumers”), describes the rights of Consumers under the California Consumer Privacy Act of 2018 (“CCPA”), and explains how Consumers may contact Gooder Foods to exercise those rights. This policy only applies to the personal information of Consumers (i.e., California residents).

Consumer Rights This section describes certain rights of Consumers under the CCPA. For information on how Consumers may contact Gooder Foods to exercise these rights, please see the section below entitled, “How to Submit a Request.” 

Right to Know A Consumer has the right to request that a business disclose what personal information it collects, uses, discloses or sells. Specifically, a Consumer may request that a business that collects personal information about the Consumer disclose to the Consumer the following:

1. The categories of personal information it has collected about that Consumer.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting or selling personal information.
4. The categories of non-affiliated entities with whom the business shares personal information.
5. The specific pieces of personal information it has collected about that Consumer.

A Consumer may request that a business that sells the Consumer’s personal information, or that discloses it for a business purpose, disclose to that Consumer:

1. The categories of personal information that the business collected about the Consumer.
2. The categories of personal information that the business sold about the Consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
3. The categories of personal information that the business disclosed about the Consumer for a business purpose.

Right to Request Deletion A Consumer has the right to request that a business delete any personal information about the Consumer which the business has collected from the Consumer. If it is necessary for Gooder Foods to maintain the personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it. 

Right to Opt-Out of Sale of Personal Information The collection of data through certain third-party cookies for Gooder Foods’ targeting advertising purposes is considered a “sale” under the CCPA. While Gooder Foods does not sell Consumers’ personal information in the traditional sense for money, we do use third party cookies for targeted advertising purposes. To opt-out of having your information shared with third party digital advertising vendors for this purpose, please refer to the section “How to Submit a Request” below.

No Discrimination A Consumer has the right not to be discriminated against because the Consumer exercised any of the Consumer’s rights under the CCPA. Gooder Foods may charge a Consumer a different price or rate, or provide a different level or quality of goods or services to the Consumer, if that difference is reasonably related to the value provided to the Consumer by the Consumer’s data. For more information, see the section titled “Notice of Financial Incentive” below.

How to Submit a Request To exercise the right to know and deletion rights described above, you must submit a verifiable Consumer request to us. You can do so by emailing us at privacy@goodles.com or contacting us at the address listed at the bottom of this Privacy Policy. Please include “CCPA” in the subject line and detail your request in the body. To exercise the right to opt-out of the “sale” of your personal information, please email us at privacy@goodles.com or click here: Do Not Sell My Personal Information. You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period. 

If you maintain an online account with us, we will verify your identity for a request through the normal account authentication process.  To submit a verifiable Consumer request, you will be asked to provide certain information to help us verify your identity. Once you submit your request via email, we will require you to email us from the email address you previously provided to us or used to communicate with us. 

You may make a verifiable Consumer request on behalf of your minor child. You may also designate an authorized agent to make a request on your behalf by submitting your authorization to us via a verified form of communication, such as through the email address you previously provided to us or previously used to communicate with us.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request. 

How we collect, use and share personal information of Consumers Gooder Foods has collected the following categories of personal information about Consumers in the twelve (12) months prior to the effective date of this policy: Identifiers: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.  Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Name, address, telephone number. Some personal information included in this category may overlap with other categories. Commercial information: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.  Internet or other electronic network activity information: Including, but not limited to, browsing history, search history, and information regarding a Consumer’s interaction with an Internet Web site, application, or advertisement.  Geolocation data: Physical location or movements.  Inferences drawn from any personal information: Profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Gooder Foods collects the personal information described above from or through the following categories of sources: From you directly, including when you provide us with information over our website in our online forms or during in person surveying events; and From service providers, including companies that provide analytics services to help us understand the activity on our website.  Gooder Foods collects the personal information described above for a variety of business purposes. Gooder Foods uses the personal information:  to provide the Services to you, including processing transactions and sending related communications; to improve the Services; to operate, improve, and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us; to provide you with information about products and services that we think may be of interest to you and to learn about your interest in our products and services; for customer service, security, to detect fraud or illegal activities and for archival and backup purposes in connection with the provision of the Services; for research and analysis purposes, such as determining trends in consumption of our products and determining where our products may be in demand; to communicate with users, including to re-contact you if we have not heard from you in a while; to permit you to participate in social sharing, including social media feeds to fulfill your requests, such as those relating to ordering and payments; to comply with applicable law and legal process; purposes we disclose to you at the time we collect the information; and to enforce our Terms of Use or other applicable policies.

Gooder Foods may share the personal information described above with the following categories of non-affiliated entities: Service providers to assist us in providing our products and services to you, including service providers that: host our databases, infrastructure and website; process payments of orders made through our website; provide analytics services to help us understand the activity on our website; assist us with customer service; assist us with marketing and communications with our clients or potential clients; and assist us with the financial, regulatory and legal aspects of our business. Courts or governmental entities as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. In connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part). In the twelve (12) months prior to the effective date of this policy, Gooder Foods has: disclosed all of the categories of personal information described above for a “business purpose” (as such term is defined under California law); and “sold” the following categories of personal information: identifiers, commercial information, and internet or other electronic network activity information. 

Notice of Financial Incentive We may offer certain financial incentive programs that can result in different price or service levels, provided that such programs are reasonably related to the value of your personal information to us. For example, we may offer discounts to Consumers who sign up for our mailing list, or giveaways, sweepstakes, contests, or other similar promotional campaigns. We typically ask you to provide your email address or other contact information in order to participate in these programs or campaigns.

We offer these programs and campaigns because, among other things, the value of your personal information to us is related to the value of the free or discounted services, or other benefits that you obtain or that are provided as part of the applicable program or campaign. This value is based on the expense related to offering those services and benefits to participants, along with other factors such as whether and to what extent you take advantage of (or opt-out from) any offerings and whether we are able to use the data we collect from you.

When we offer any program or campaign, there is no obligation to opt-in, and you may withdraw at any time by contacting us using the designated method set forth in the applicable program rules or in the “Contact for More Information” section below. Please review the applicable program or campaign offering or terms to view full details, including how to join.

Contact for More Information If you have any questions or concerns about Gooder Foods’ privacy policy and practices, please send an email to privacy@goodles.com.