1. INTRODUCTiON

THINKFOODGROUP, LLC respects the privacy of users who visit the Site and their personal data. The following policies are in effect for all of the webpages operated by THINKFOODGROUP, LLC. Please read our privacy policy from time to time, since it may be modified periodically.

“Personal Data” as defined means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Keeping your personal data is one of our most important responsibilities. We will safeguard, according to established standards of security and confidentiality, any information our users share with us.

We use cookies on our website. If the cookies are not strictly necessary for the use of THINKFOODGROUP, LLC, we will ask you to consent to our use of cookies when you first visit our website.

2. HOW WE COLLECT AND USE YOUR PERSONAL DATA

a. In this section we set out:

i. The categories of personal data that we may process

ii. The reason why we may process personal data

iii. The legal basis for processing this data;

In some circumstances, THINKFOODGROUP, LLC may request personal information from you, like your name, email, company name or telephone number. We may also ask you to select a username and password or identification number to gain access to certain portions of our site. We may also ask you to provide optional demographic information such as your zip code, your age range, or your product preferences. When a visitor requests pages on the THINKFOODGROUP, LLC Site, our servers automatically recognize the browser’s domain name IP address. Our servers also record email address for reasonable business purposes.

In general, you can visit THINKFOODGROUP, LLC sites without divulging any personal information. However, there are areas of THINKFOODGROUP, LLC’ sites that require this information to complete their customization functions. These sites areas may not be available to those choosing not to reveal the information requested.

1. ANALYTICS DATA: We may collect and process data about your use of our website (‘analytics data’). The analytics data may include any of the following: your IP address; approximate location, internet browser type and version, the source of referral, length of your visit, and website navigation paths, as well as information about the frequency, and pattern of your visits. We gather this data through the Google Analytics service. The legal basis for procession this data is our legitimate interests in improving our website and service.

2. CUSTOMER DATA: We collect and process data relating to customer profiles (‘customer data’). This data includes: your full name, email address, phone number & billing address. You may be required to provide this information during the process of booking our service. The legal basis for processing this data is for the performance of the contract, in particular, for us to be able to reliably communicate with you regarding your bookings or purchases, and to provide the service you requested. All of our data is passed on to a third-party service/vendor as part of Transaction information. For more information see section 4.

3. TRANSACTION DATA: We may collect and process data relating to the payment of services through our website or customer service agents (‘Transaction Data’). Transaction data includes: card number, card expiration date and card security code, as well as some customer data: billing address and card holder’s name, we may also process some additional data to run background checks in order to reduce fraudulent activity, this data may include: your email address & telephone number. Transaction data is handled and stored by a third-party service. The transaction data may be processed for supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.

4. CORRESPONDENCE DATA: We may process information contained in or relating to any communication that you send to or have with us (‘correspondence data’). The correspondence data may include: email content, online chat transcripts, call recordings and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you. Where possible we avoid collecting transaction data in correspondence data, this is done via warning notices on emails and pausing call recordings during the payment. The legal basis for this processing is in the performance of a contract, namely to organize and supply the purchased services. Correspondence data is handled and stored by a third-party vendor.

5. We may process any of your personal data where necessary, for use in the defense of legal claims in court or another legal proceeding. The legal basis for this is to protect and assert our legal rights, the rights of our customers’ or the rights of others.

6. We may process any of your personal data where such processing is necessary to comply with a legal obligation to which we are subject, or to protect your interests or the interests of another person.

7. We may process information regarding your Social Media Information and content. If you access or log into a service through a social media service or connect a service to social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information you have permitted the social media service to share with us, such as your profile picture email address, or friends lists, and any information you have made public in connection with that social media service. When you access the services through social media, you are authorizing THINKFOODGROUP, LLC through its third-party, to collect, store, and use such information and content in accordance with this Privacy Policy. The legal basis for processing this data is for the performance of the contract, in particular, for us to be able to reliably communicate with you regarding your bookings or purchases, and to provide the service you requested.

3. THE STEPS WE TAKE TO PROTECT YOUR PERSONAL DATA

We have a security team dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.

4. THIRD PARTY SERVICE/VENDOR

1. We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide the Services to you. Unless we tell you differently, such third parties do not have any

right to use the Personal information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our Services, including the provision of maintenance services, database management, web analytics and general improvement of the Services. In particular, as part of our provision of the Services to you, we provide a limited amount of your End User Customer Information to our third-party vendors so that our third-party vendors can collect and compile publicly available contact and social media information related to your End User Customers, such as email addresses, gender, company, job titles, photos, website URLs, social network handles and physical addresses.

2. Transactional Information: Financial transactions relating to our website and services are OR may be handled by our payment services providers, In-store, handled by our third-party payment service providers. THINKFOODGROUP, LLC has the right to choose its third-party vendors and those details can be made available by contacting digital@thinkfoodgroup.com. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices on their websites.

3. We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.

4. We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

5. RETAINING AND DELETING PERSONAL DATA

This section sets out our data retention policies, these are designed to ensure that we comply with our legal obligation in relation to the retention and deletion of personal data and are designed so that we maintain the lowest possible level of risk to our customers.

Personal data that we process for any purposes shall not be kept for longer than is necessary to fulfill the purchased service and our third-parties legal obligations.

We will retain and delete your personal data as follows:

1. Analytics Data:

a. Google Analytics retains data relating to a visit to our website indefinitely. The data collected is non-identifiable. We collect some identifiable analytics data, this is stored for at least five years following a visit to our website, at the end of which period it will be deleted from our system.

2. Customer Data will be retained for the standard and legal time allowed, unless customer request to have personal information deleted.

6. YOUR RIGHTS

If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us using the mechanisms provided below. We will try to comply with your request as soon as reasonably practicable.

You may opt out of having your personal information used or disclosed for certain purposes:

1. If you no longer want to receive marketing-related emails from us on a going-forward-basis, you may opt-out of receiving these emails by clicking “unsubscribe” or “update my preferences at the bottom of any marketing email you receive.

2. If you would prefer that we do not share your personal information on a going-forward basis with business partners for their direct marketing

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party.

You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with our lead supervisory authority:

Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

7. CHILDREN

We do not collect personal information from any person we actually know is under the age of 17 without the consent of the parent or legal guardian of that minor. A parent or guardian may consent to the use of THINKFOODGROUP,LLC, by a minor, which parent or guardian is solely responsible for providing supervision of the minor’s use of THINKFOODGROUP, LLC and assumes full responsibility for the interpretation and use of any information or suggestions provided through THINKFOODGROUP, LLC . If you believe we might have any information from or about a child under 17, please contact us at digital@thinkfoodgroup.com. If we learn and have confirmation we have collected or received personal information from a child under 17 without verification of parental consent, we will delete that information.

8. COOKIES

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We use cookies and similar technologies to recognize you and/or your device(s) on, off and across different Services and devices. We also use them to track web analytics. You can control cookies through your browser settings and other tools. you can also opt-out using similar technology.

9. MOBILE DEVICES

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

10. CALIFORNIA LAW RIGHTS

Under California law, California residents who have provided personal information to a company may have the right to request a list of all third parties to whom that company had disclosed such information for the third parties’ direct marketing purposes during the preceding calendar year, along with a list of the categories of personal information that had been so disclosed. However, if a company adopts and discloses a privacy policy that provides the ability to opt-out of such disclosures to third parties for the third parties’ direct marketing purposes, then the company is not required to maintain and provide such lists, and instead may provide you with information on how to exercise your right to prevent disclosure of your personal information. Because the privacy policy as disclosed on this Site provides you with an opportunity to opt-out of disclosures by us of your personal information to third parties for their direct marketing purposes, we do not have to provide you with such lists. If you are a California resident who would like information on how to exercise your rights concerning third party disclosures, you may contact THINKFOODGROUP, LLC, at 202.638.1910.

11. BEACONS

Web Pages and HTML emails may contain a small snippet of code called a web beacon. In their simplest form, web beacons allow a website to transfer or collect information through a graphic image request. Websites may use web beacons and cookies for many purposes, including site usage analytics, advertising auditing and reporting, and content and advertising personalization.

THINKFOODGROUP, LLC may collect information through web beacons about how you interact with our html email marketing campaigns. This may include your IP address and the date / time that you opened or interacted with an html email. We may use the information we collect through web beacons:

• To determine which email messages sent by THINKFOODGROUP, LLC were opened and to note whether a message was acted upon.

• To understand how you use and interact with THINKFOODGROUP, LLC products and services.

• To improve THINKFOODGROUP, LLC products and services.

• To optimize your html email experience.

• To provide you relevant content.

12. OUR DETAILS

THINKFOODGROUP, LLC is registered in Delaware and our principal place of business is Washington D.C. You can contact us via email at info@thinkfoodgroup.com or phone 202.638.1910.

13. AMENDMENTS

This Privacy Policy will be updated periodically to reflect changes in technology, law, our business operations, or any other reason we determine necessary or appropriate.

THINKFOODGROUP, LLC respects the privacy of users who visit the site. The following policies are in effect for all of the webpages operated by THINKFOODGROUP, LLC. Please read our Privacy Policy from time to time, since it may be modified periodically.

14. CONTACT THINK FOOD GROUP

If you need to contact us regarding our Privacy Policy or to access personal identifiable information submitted on our site, please contact:

Think Food Group
717 D Street, NW
Washington D.C 20004
ATTN: Digital
E-mail: digital@thinkfoodgroup.com

Privacy Notice for California Residents

Effective Date: December 2019
Last Reviewed: December 2019

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category A: Identifiers
Examples: A real name, Internet Protocol address, email address, or other similar identifiers.
Collected: YES

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: NO

Category C: Protected classification characteristics under California or federal law.
Examples: 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).
Collected: NO

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete on our website.
• Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to make a reservation or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose [or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights)]. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. [The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.]

We share your personal information with the following categories of third parties: OpenTable, our online reservation tool. Please see https://www.opentable.com/legal/privacy-policy for their privacy policy.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.

Sales of Personal Information
In the preceding twelve (12) months, Company had not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to [45/90] days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at our address listed on our webpage.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and uses your information described below [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows

• Via our website: please send us an electronic message through our website
• Write us at our address:
  Think Food Group
  717 D Street, NW
  Washington D.C 20004
  ATTN: Digital