Effective July 2024

We may collect other information that you voluntarily share with us to facilitate our use of the Site or our Services which is not specifically listed here. We will use such information in accordance with this Policy, as otherwise disclosed at the time of collection, in accordance with our agreement with you, or to the extent necessary for providing the Site or our Services.

3. How We May Use Your Personal Information

We may use the information described above, including any personal information, in connection with the following purposes or otherwise to the extent permitted by law:

• Provide Our Services to You: We use your information to provide you with our Services, which includes making our Site and our Services available to you; to serve you the content and functionality you request; to offer you goods and services which may be of benefit to you; to process orders and payments; to communicate about our Services and responding to your feedback, requests, questions, or inquiries; to enhance your experience and provide you with a more personal and interactive experience; to improve and developing existing and new Services, including evaluations of functionality and features and recognizing your devices and remembering your preferences and interactions; to ensure the privacy and security of our Site, Services, and operations.
• Operating Our Business: We use your information to operate our business which includes to obtain or maintain insurance coverage, managing risks, obtaining professional advice, to mitigate risks to the privacy and security of our Site, Services, and operations, including fraud or phishing detection, to maintain our databases and back-ups; enforce our Terms of Use, comply with any contractual obligations; and to manage our relationships with you.
• Communicating With You: We use your information to communicate with you, such as to contact you directly by mail, telephone, email, SMS, or other electronic messaging service in order to respond and provide the appropriate assistance and response to you; to extend offers of goods and services or information that may be of interest to you; to keep records of our communications with you; to determine user interests; for usage analytics purposes; and to administer a promotion, survey, or other customer engagement features. You may unsubscribe from certain communications at any time. Please see the “Your Rights and Choices Regarding Your Personal Information” Section of this Policy for more information.
• Improving Your Experience, Marketing and Advertising: We use your information to tailor our products and services so that they are more relevant to you; to understand your preferences and provide and improve support related to our products and service offerings; to promote and advertise our products and services, including through third-party websites or online services; to assess the success of our marketing campaigns and enhance our marketing efforts; and to conduct research and analysis for marketing, business, and other operational purposes.
• Fraud, Security, Legal Enforcement and Compliance: We use your information to protect the security and integrity of our business, the Site and our Services, such as to enforce our agreements with you, to comply with federal, state, or local laws; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons; to cooperate with law enforcement agencies concerning conduct or activity that we may believe violates applicable law; and to establish, exercise, defend legal rights or claims, whether in court, administrative, or other proceedings.

We do not use your personal information for making any automated decisions affecting or recreating profiles other than as described above.

We may also use your information to accomplish any other ancillary purpose related to any of the purposes described in this Policy for which your personal information was provided to us or for which we have a legal basis under applicable law. We may combine personal information about you with other information we have acquired from third parties in accordance with applicable law and will treat the combined information as personal information under this Policy.

We may create, disclose, and otherwise use information as de-identified or aggregated data which, upon aggregation and de-identification, are no longer treated as personal information subject to this Policy.

4. How We May Disclose Your Personal Information

We may disclose your personal information described above in the following contexts:

• Service Providers: We may share your personal information with our third-party service providers who perform a variety of functions on our behalf or at your direction for the purposes described in this Policy. This includes, but is not limited to, development, administration, and maintenance of the Site, support our provision of Services requested by you, provide technical support, sending marketing, promotions, and communications to you about our Services, provide payment processing, enhance the security of our Site, marketing and advertising services, and assisting with other legitimate purposes permitted by law.
• We may also disclose the personal information we collect to our analytics vendors and partners to develop aggregate analytics and business intelligence for our advertising and marketing purposes. For example, we use personal information to create custom audiences and measure the success of promotions.
• When you watch videos on the Site, you agree that we may disclose your video viewing to or obtain information about your video viewing from analytics service providers, advertising partners, and social media platforms.
• Corporate Affiliates: We may share your personal information with our subsidiaries or affiliates, and with their respective officers, directors, employees, accountants, attorneys, and agents to provide our products and services and for our marketing purposes in accordance with applicable law.
• Acquisition and Similar Transactions: If we sell, transfer, or otherwise share some or all of our assets in connection with a merger, reorganization, liquidation, dissolution, bankruptcy, or sale of assets, we may disclose your personal information as a part of the assets transferred as a result of the transaction. For example, if another company acquires us, we will share your personal information with that company.
• In Response to Legal Process or Defending Legal Claims: We may disclose personal information as required by law, court orders, subpoena, or other legal process or if we reasonably believe such action is necessary to comply with the laws.
• Professional Advisors: We may share your personal information with our attorneys, accountants, and/or other fiduciaries and consultants who need access to your information to provide operational or other support on our behalf.
• Public: Some areas of our Site provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit your personal information in these areas, you do so at your own risk and acknowledge that the information will be publicly available.
• With Your Consent or at Your Direction: We may ask, from time to time, if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We may disclose your information in this context with your permission or upon your direction.
• Deidentified or Aggregated Data: We may share aggregated information, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for compliance with reporting obligations; for business or marketing purposes; and to assist us and others in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, marketing, and/or functionality.

5. Cookies and Similar Technologies

We use cookies and similar technologies on the Site to, among other things, provide you with a more personal and interactive experience on our Site, to improve our marketing efforts, and for usage analytics for our Site (e.g., page response times, download errors, length of visit, webpages visited, etc.). Please see our Cookies and Similar Technologies Policy: https://www.truelemon.com/pages/cookie-policy/ for more information. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.

6. How Long Do We Retain Your Personal Information?

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our Services, and enforce our agreements.

We take reasonable steps to delete the personal information we collect when: (1) we have a legal obligation to do so; (2) we no longer have a purpose for retaining the information; or (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

To the extent permitted by law, we may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.

7. Security and Protection Of Your Personal Information

We recognize the importance of safeguarding your personal information and we endeavor to maintain reasonable and appropriate physical, technical and organizational safeguards to prevent your personal information against accidental loss and unauthorized access, use, alteration, or disclosure, and to mitigate risks concerning your personal information.

While our security measures seek to protect your personal information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Site or otherwise through our Services. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone. We are not responsible for circumvention of any privacy settings or security measures contained on the Site and Services.

8. Your Rights and Choices Regarding Personal Information

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor such requests when we are required to do so under applicable law.

Accuracy and Updating Your Information.

Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please let us know or otherwise update it in your user account through our Site. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that you provide to us.

Email Opt Out.

If you no longer wish to receive communications from us via email, you may opt out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us via the “Contact Us” details at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.

Text Messages (SMS) Opt Out.

We ask for your consent to receive text messages (including messages related to the Services or transaction requested by you or our other products or Services that may be of interest to you). Certain text messages may be sent by automated systems or technology. You may unsubscribe from marketing text messages at any time by replying STOP or clicking the unsubscribe link (where available) in the text messages.

Cookies.

You may be able to set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. You may also adjust your cookie preferences by using the cookie consent banner or by visiting our Cookies and Similar Technologies Policy. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.

Do Not Track.

Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions.

Complaints.

If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

9. Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the CCPA Privacy Policy for California residents here: https://www.truelemon.com/pages/privacy-policy-california.

Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of the Site may make any changes to their information at any time by contacting us at customercare@truecitrus.com.

10. Your Individual Rights

In addition to the California Privacy Rights described above, to the extent you are a resident of certain U.S. states with comprehensive state privacy laws, you may be eligible for one or more of the following consumer rights where authorized by applicable U.S. state privacy laws. This section provides an overview of those rights which we honor where required by applicable law.

Right to Access.

Subject to certain conditions set forth in the applicable U.S. state privacy laws, you have the right to know and see what personal information we have collected about you and receive a copy of such information in a portable format, purposes for which we collect your personal information, recipients of your personal information to whom we disclose or share, which in some states may include categories of personal information collected, categories of sources of collection, business or commercial purposes for data processing, and categories of third parties with whom we disclose that information.

Right to Correct.

Subject to certain conditions and exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we correct any inaccurate personal information that we have collected about you.

Right to Delete.

Subject to certain conditions and exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we delete the personal information we have collected about you.

Right to Opt-Out.

Subject to certain conditions set forth in the applicable U.S. state privacy laws, you have the right to opt out of targeted advertising, profiling and the sale or sharing of your personal information to the extent such instances occur (as defined under applicable state laws). We do not have actual knowledge that we sell personal information of minors under 16 years of age.

Right to Non-Discrimination.

You have the right not to be discriminated against for exercising any of your rights under any applicable U.S. state privacy laws.

Right to Appeal.

To the extent the applicable U.S. state privacy laws provide such rights, you may appeal our denial to act on your consumer rights under the applicable state privacy laws within a reasonable time. We will respond within the designated period for responding to U.S. data subject requests and may exercise the right to extend this response period (to the extent authorized by applicable state privacy laws).

Right to Limit Use and Disclosure of Sensitive Personal Information.

If any U.S. state privacy laws classify your personal information we collect as “sensitive personal information,” we use such data reasonably necessary to provide and perform our Services as requested by you or as otherwise permitted by law.

Right to Object.

Subject to certain conditions and exceptions set forth in applicable U.S. state privacy laws, you have the right to object to the processing of your personal information and to ask us to erase or restrict our use of your personal information.

Right to Withdraw Consent.

If you have provided your consent to the collection, processing and transfer of your personal information, you have the right to fully or partially withdraw your consent. To withdraw your consent, please notify us using the information in the Contact Us section of this Policy and you may follow opt-out links on any marketing communications sent to you.

Once we have received notice that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.

If you have questions or concerns regarding this Section or would like to exercise your consumer rights (to the extent available under applicable U.S. state privacy laws), please use the “Contact Us” details at the end of this Policy.

11. Children’s Privacy

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and Services are not directed to children aged 18 or younger, nor is information knowingly collected from children under the age of 18. No one under the age of 18 may access, browse, or use the Site or provide any information to or on the Site. If you are under 18 years of age, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, and username). If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 18 without his/her parent’s consent, please contact us using the contact information provided below.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

12. Links To Third-Party Sites

This Policy is applicable only to the Site and Services. It does not apply to any third-party websites or applications.

This Site may contain links to, and media and other content from, third-party websites. These links are to external resources and third parties that have their own privacy policies. Because of the dynamic media capabilities of the Site and Services, it may not be clear to you which links are to external, third-party resources. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site.

We cannot and do not (i) guarantee the adequacy of privacy, security, practice content or media provided by third parties or their websites, (ii) control third parties’ independent collection or use of your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Site.

Any personal information provided by you or automatically collected from you by a third-party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website or application.

13. Updates And Changes To This Policy

We reserve the right, at any time and without notice, to add to, change, update, or modify this Policy to reflect any changes to the way in which we treat your personal information or in response to changes in law. Should this Policy change, we will post all changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will also notify you through a notice on the home page of the Site for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting on the Site. The date on which this policy was last modified is identified at the beginning of this Policy.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, engaging with us on social media, or communicating with us, from time to time, so that you are aware of any changes. Your continued use of the Site, engaging with us on social media, or communicating with us in any format after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your personal information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, you should not use the Site or our Services.

14. How To Contact Us

For more information, or if you have questions or concerns regarding our Site, Privacy Policy, or practices, please contact us at:

Email: customercare@truecitrus.com

U.S. postal address:

Attn: True Citrus Consumer Affairs

True Citrus Company

11501 Pocomoke Court

Suite D

Baltimore, Maryland 21220