- What information do we collect from you (referred to as “you” or “users” or “your”)?
- Where do we collect information from you and how do we use it?
- With whom do we share your information?
- How can you update, correct or delete your Personally Identifiable Information?
- What are your choices regarding collection, use and distribution of your information?
- What security precautions are in place to protect against the loss, misuse or alteration of your information?
- Do we use "cookies"?
- What should you know about privacy policies and data collection at any third-party sites accessible from our Site?
- What else should you know about your privacy online?
- California Online Privacy Protection Act (COPPA)
- EU Privacy Notice
1. What information do we collect from you?
In order to better provide you with our numerous services, we collect two types of information about our users: Personally Identifiable Information and Non-Personally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient and customized experience while using our Site.
Personally Identifiable Information (PII): This refers to information that lets us know the specifics of who you are and is information you provide to us while using our Site.
Non-Personally Identifiable Information (NPII): This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the website's Uniform Resource Locator ("URL") that you just came from, which URL you go to next, what browser you are using and your Internet Protocol ("IP") address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol ("TCP/IP") network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.
2. Where do we collect information from you and how do we use it?
We do not collect any PII about you unless you voluntarily provide it to us. You provide certain PII to us when you engage in certain activities on this Site, such as registering your email address with us, sending email messages, entering sweepstakes or contests sponsored by us or one of our partners, submitting data, posting content in discussion forums or other public areas, filling out a survey, sending us feedback, or requesting information/assistance, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), email address, employer, type of establishment, job title, telephone number and other personal identifying information, as required to suit the purposes of the collection intent. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer our Site and to gather demographic information.
3. With whom do we share your information?
We do not, and will not ever, sell, trade, or rent your PII to others. We do provide some of our services through contractual arrangements with affiliates, service providers, partners and other third parties. We and our service partners use your PII to operate our Sites and to deliver their services. We encourage our service partners to adopt and post privacy policies. The use of your PII by our service partners, however, is governed by the privacy policies of those service partners and is not subject to our control.
Occasionally we may be required by law enforcement or judicial authorities to provide PII to the appropriate governmental authorities. We will disclose PII upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.
4. How can you update or correct your Personally Identifiable Information?
We believe you should have the ability to access and edit the PII that you have provided to us. You may change any of your PII in your account online at any time by clicking the EMAIL PREFERENCES link within all email communications. You may also access and correct your personal information and privacy preferences by writing us through the Contact Us section of our Website:
Please include your name, address and/or email address when you contact us. We encourage you to promptly update your PII if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on this Site. In addition, it may be impossible to completely delete your information without some residual information because of backups.
5. What are your choices regarding collection, use and distribution of your information?
We may, from time to time, send you emails regarding our services. In addition, if you indicated upon registration that you are interested in receiving information from us and our partners, we will send you emails about avocado recipes and product information that we feel may be of interest to you. Only the COMMISSION will send you these direct mailings and only if you opted-in to receive these communications. If you do not want to receive such mailings, you may unsubscribe at any time using the UNSUBSCRIBE link at the bottom of every email. Or, at any time you can easily edit your account information to no longer receive such communications using the links at the bottom of these communications.
You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. If you choose to reject all cookies some parts of our Site may not work properly.
6. What security precautions are in place to protect against the loss, misuse or alteration of your information?
On our Site you can be assured that your PII is secure, consistent with current industry standards. The importance of security for all PII associated with our users is of the utmost concern to us. Your PII is protected in several ways. You can request your PII at any time by writing us through the Contact Us section of our Website:
Please include your name, address and/or email address when you contact us.
We encrypt your PII and thereby prevent unauthorized parties from viewing such information when it is transmitted to us.
Personal information that you provide that is not PII also resides on a secure server and is only accessible via password. Since this information is not accessible from outside the Commission you will not be asked to select a password in order to view or modify such information.
No data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your PII, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
7. Do we use "cookies"?
When you use our Site we will store cookies on your computer in order to facilitate and customize your use of our Site. A cookie is a small data text file, which a Website stores on your computer's hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located and your first name to welcome you back to our Site. The cookies make your use of the Site easier, make the Site run more smoothly and help us to maintain a secure Site. You are always free to decline our cookies if your browser permits, but some parts of our Site may not work properly in that case.
8. What should you know about privacy policies and data collection at any third-party sites accessible from our Site?
9. What else should you know about your privacy online?
You must be at least 18 years old to have our permission to use this Site. Our policy is that we do not knowingly collect, use or disclose PII about visitors that are under 18 years of age.
You should also be aware that when PII is voluntarily disclosed (i.e. your name, email address, etc.) in the discussion forums or other public areas on this Site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas on this Site are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you are online.
CaliforniaAvocadoGrowers.com displays retargeted ads to our Site prospects across the Internet. We collect NPII about your visits to our Website and your interaction with our products and services. The anonymous information is collected through the use of a pixel tag, which is industry standard technology used by most major Websites. No PII is collected during this process.
10. California Online Privacy Protection Act (COPPA)
Under the COPPA, you are entitled to ask us annually for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom the business has shared such information during the immediately preceding calendar year.
According to COPPA, we agree to the following:
- Users can visit our Site anonymously.
- We will have a link to this Policy on our home page or at a minimum, on the first significant page after entering our Website.
11. EU Privacy Notice
If you are a resident of the European Union (EU) or European Economic Area (EEA) whose personal information we collect, the following additional information applies to you.
1.1 - Where you are an EU or EEA resident and California Avocado Commission knowingly collects your personal information (also called 'personal data'), we will do so in accordance with applicable laws that regulate data protection and privacy. This includes, without limitation, the EU General Data Protection Regulation (2016/679) ('GDPR') and EU member state national laws that implement or regulate the collection, processing and privacy of your personal data (together, 'EU Data Protection Law').
1.3 - This Privacy Notice also provides information on your legal rights under EU Data Protection Law and how you can exercise them.
- How personal data is collected
2.1 - California Avocado Commission may hold and process personal data that is collected from organizations around the world, including within the EU/EEA.
2.2 - This is to make sure that the personal data that California Avocado Commission receives and processes (so far as it relates to residents of the EU/EEA) is properly safeguarded in accordance with similar legal standards of privacy you would enjoy under EU Data Protection Law.
- Direct Marketing
3.1 - If California Avocado Commission provides direct marketing communications to individuals in the EU/EEA regarding services and/or events which may be of interest, this will be done in accordance with EU Data Protection Law, and in particular where we contact individuals for direct marketing purposes by SMS, email, fax, social media and/or any other electronic communication channels, this will only be with the individual's consent or in relation to similar services to services that the individual has purchased (or made direct enquiries about purchasing) from California Avocado Commission before.
3.2 - Individuals are also free to object or withdraw consent to receive direct marketing from us at any time, by contacting us using the email address below.
- The lawful grounds on which we might collect and process personal data
4.1 – If we process your personal data for the above purposes, we will rely on one or more of the following lawful grounds under EU Data Protection Law:
(a) where you have freely provided your specific, informed and unambiguous consent for California Avocado Commission to process your personal data for particular purposes:
(b) where we agree to provide services to you, in order to set up and perform our contractual obligations to you and/or enforce our rights:
(c) where we need to process and use your personal data in connection with our legitimate interests as a global network and being able to effectively manage and operate our organization in a consistent manner across all territories. We will always seek to pursue these legitimate interests in a way that does not unduly infringe on your legal rights and freedoms and, in particular, your right to privacy: and/or
(d) where we need to comply with a legal obligation or for the purpose of us being able to establish, exercise or defend legal claims.
4.2 - Please also note that some of the personal data we receive and that we process may include what is known as 'sensitive' or 'special category' personal data about you, for example, information regarding your ethnic origin or political, philosophical and religious beliefs. This is not the type of data that California Avocado Commission would routinely collect, but if we process such sensitive or special category data, we will only do this in specific situations where:
(a) you have provided this with your explicit consent for us to use it: or,
(b) there is a legal obligation on us to process such data in accordance with EU Data Protection Law
(c) it is needed to protect your vital interests (or those of someone else) such as in a medical emergency: or,
(d) where you have clearly chosen to publicize such information: or,
(e) where needed in connection with a legal claim that we have or may be subject to.
- Disclosing your personal data to third parties
5.1 - We may disclose your personal data to certain third party organizations who are processing data solely in accordance with our instructions (called 'data processors') such as companies and/or organizations that support our operations (for example providers of web or database hosting, IT support, payment providers, event organizers, agencies we use to conduct fraud checks or mail management service providers) as well as professionals we use such as lawyers, insurers, auditors or accountants. We only use those data processors who can guarantee to us that adequate safeguards are put in place by them to protect the personal data they process on our behalf.
5.2 - We may also disclose your personal data to third parties who make their own determination as to how they process your personal data and for what purpose(s) (called “data controllers”). The external third party data controllers identified above may handle your personal data in accordance with their own chosen procedures and you should check the relevant privacy policies of these companies or organizations to understand how they may use your personal data.
5.3 - Other than as described above, we will treat your personal data as private and will not routinely disclose it to third parties without you knowing about it. The exceptions are in relation to legal proceedings or where we are legally required to do so and cannot tell you (such as a criminal investigation). We always aim to ensure that your personal data is only used by third parties we deal with for lawful purposes and who observe the principles of EU Data Protection Law.
- How long we retain your personal data
6.1 - California Avocado Commission retains personal data identifying you for as long as necessary in the circumstances.
6.2 – The personal data that we no longer need will be disposed of and/or anonymized so you can no longer be identified from it.
- Your personal data rights
7.1 - In accordance with your legal rights under EU Data Protection Law, you have a 'subject access request' right under which can request information about the personal data that we hold about you, what we use that personal data for and who it may be disclosed to as well as certain other information.
7.2 - Usually we will have one month to respond to a subject access request. However, we reserve the right to verify your identity and we may, in case of complex requests, require a further two months to respond. We may also charge for administrative time in dealing with any manifestly unreasonable or excessive requests. We may also require further information to locate the specific information you seek and certain legal exemptions under EU Data Protection Law may apply when responding to your subject access request.
7.3 - Under EU Data Protection Law. EU/EEA residents also have the following rights. which are exercisable by making a request to us in writing:
(a) that we correct personal data that we hold about you which is inaccurate or incomplete:
(b) that we erase your personal data without undue delay if we no longer need to hold or process it:
(c) to object to any automated processing (if applicable) that we carry out in relation to your personal data. For example, if we conduct any automated credit scoring:
(d) to object to our use of your personal data for direct marketing:
(e) to object and/or to restrict the use of your personal data for purpose other than those set out above unless we have a compelling legitimate reason: or
(f) that we transfer personal data to another party where the personal data has been collected with your consent or is being used to perform contract with you and is being processed by automated means.
7.4 - So we can fully comply, please note that these requests may also be forwarded on to third-party data processors who are involved in the processing of your personal data on our behalf.
7.5 - If you would like to exercise any of the rights set out above, please contact us at the address below.
7.6 - If you make a request and are not satisfied with our response, or believe that we are illegally processing your personal data, you have the right to complain to the Office of the Information Commissioner in the United Kingdom.
California Avocado Commission
Attn: Legal Department
12 Mauchly, Suite L
Irvine, CA 92618-6305
Telephone: (949) 341-1955