MORTON’S GOURMET MARKET PRIVACY POLICY

PRIVACY & DATA USE

Your privacy is important to us. Any and all information collected on this site will be kept strictly confidential and will not be sold, disclosed to third parties, or reused without your permission. To fully optimize our engagement with our Loyal Local Program we will only ask for your Name, Address, Phone Number, Email Address, and Birthday.

Any information you give to us will be held with care and will not be used in ways that you have not consented to. If you are dissatisfied for any reason, Morton’s Gourmet Market would like to know — please send us a message to service@mortonsmarket.com and we will immediately address your concern.

We do not sell or rent your personal information. We may share information with service providers solely to facilitate messaging services. Our policy complies with applicable U.S. privacy laws.

We strive to deliver outstanding products and services and value our customers’ business and loyalty. We recognize that privacy is an important issue. We have developed this Policy to explain our practices regarding the personal information we collect from you or about you when you purchase products from us, through written or verbal communications with us, when you use this website or mobile applications.

By accessing or using our websites, mobile applications (“apps”), or submitting information to us, or otherwise agreeing to this Policy, e.g., in the context of registering for any of our products or services, you understand and consent to our collection and use of your personal information as described herein.

PERSONAL INFORMATION WE COLLECT AND USE Personal information is information that identifies, relates to or describes you or can reasonably be associated with or linked to you. We collect personal information directly from you through our websites and apps and in our contact with you at our stores. We may also collect information related to conversations, including records or copies of your correspondence with us or customer service calls for quality assurance and training purposes, and other communications such as website chat support, in- app messages, or SMS.

We collect and use personal information in certain common cases, including:

purchasing preferences. The personal information described in this paragraph is the “Purchase Data.”

We provide customer service at our stores, by telephone and through our website. In providing customer service we may collect personal information from you such as name, address, e-mail address, telephone, product purchases, product sales, and other information related to your service request. We use this information in order to investigate, resolve and respond to your customer service issue. The personal information described in this paragraph is the “Customer Service Data.

Loyalty Membership
When you apply for the Loyalty program and exercise your rights and benefits, we collect personal information which may include first name, last name; address, e-mail address; telephone number; mobile device number, internet protocol address, date of birth. We use this information to provide you with the features and benefits of our membership program and information about our goods and services. The personal information described in this paragraph is “Membership Data.”

Social Media
If you choose to participate in one of our sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates, and friends list. We may also allow you to enter into contests to provide photos, such as of products you have purchased, which you may share with your connections on social media for votes, shared offers or other promotions. We use this information for providing information about our goods and services and for understanding the needs and preferences of our customers. The personal information described in this paragraph is the “Social Data.”

Contests
We may run contests in which you may choose to participate. The personal information we collect may include first name, last name, e-mail address, telephone number, address, date of birth and other individual responses as indicated at the time of collection. Prize winners may be required to provide a social security number for tax reporting purposes. We use this information to facilitate the contest or sweepstakes. The personal information described in this paragraph is the “Contest Data.”

Customer Surveys
We may collect personal information at various events through surveys in which you may choose to participate. The information we collect may include age; date collected; purchase history, habits, and preferences; email; first name; last name; and other individual survey responses as indicated at the time of collection. We use this information to understand the needs and preferences of our customers so that we can improve our goods and services. The personal information described in this paragraph is the “Survey Data.”

Security
Our stores use security cameras to monitor the activity of our customers and staff. The information we collect includes video recordings. Audio is not recorded. The camera images are not monitored in real time. The recordings are viewed only if there is reason to believe that there has been a breach of security. We use this information to detect security incidents and to report to law enforcement agencies. The personal information described in this paragraph is the “Security Data.”

Automatically Collected Personal Information
By its nature, our websites also automatically collect some personal information about you. In order for you to view or interact with our website or apps, we receive individual identifiers like your IP address, and some network information like the date and time that pages are visited. We may collect this personal information even if you are not logged in. We collect some personal information automatically using cookies or other tracking technologies as described below in Section 7. The personal information automatically collected may be collected by or on behalf of third parties who may provide us with inferences or aggregate reporting based on analysis of such personal information. We use this information to understand how our customers are using our websites and apps. The personal information described in this paragraph is the “Use Data.”

Employees
We collect personal information in the context of your role as an applicant to, an employee of, director of, or officer of, our business. The personal information we collect in these cases may include name, alias, social security number, address, email address, online identifier, driver’s license number, state identification card number; passport number, immigration status, alien registration card number, date of birth, birth certificate, citizenship status, gender, marital status, race, ethnicity, bank account and routing number, tax filing status, emergency contact information, telephone number, family member names, educational background, criminal background and employment history, employment status, veteran/military status, employee ID, fingerprint, performance evaluations, garnishments, medical provider information, dependent name(s), date of birth, gender and address, medical insurance information, compensation and benefits data, workplace, and title. We only use this information for purposes of evaluating qualifications related to your job application or your job duties; evaluating your performance; or for providing compensation, benefits and services in the context of the employment relationship. The personal information described in this paragraph is the “Employee Data.”

PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

We may collect your personal information for the following purposes:

Auditing
Auditing related to a current interaction with you, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;

Security
Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

Debugging
Debugging to identify and repair errors that impair existing intended functionality;

Transient Use
Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with us provided that your personal information is not disclosed to a third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;

Services
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage or providing similar services on our behalf;

Advertising
Providing advertising and marketing services to you.

Research
Research. Undertaking internal research for technological development and demonstration;
and

Quality and Safety
Undertaking activities to verify or maintain the quality or safety of our products and services and to improve, upgrade, or enhance our products and services.

Commercial Interests
Advancing our commercial or economic interests, such as by inducing a person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

LIMITED USE OF PERSONAL INFORMATION

We will only use your personal information for the purposes for which we have collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider de-identification, aggregation, and other forms of anonymization of personal information to be compatible with the purposes listed above, and in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information.

If you wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact us via the information specified in the Contact section below.

OUR DISCLOSURE OF PERSONAL INFORMATION

In order to provide you with the best products and services, we disclose your personal information to our affiliates, service providers, contractors and other third parties as described below.

Affiliates
We may disclose your personal information to our parent company and entities under shared corporate control (“Affiliates”) for the purposes described in Sections 2 and 4 above.

Contractors
We disclose personal information to entities that help us fulfill a business or commercial purpose including, but not limited to, shipping companies that deliver our products to you (“Contractors”). Contractors are not permitted to sell or share your personal information or to use your personal information other than to perform the tasks we assign to them.

Service Providers
We disclose your personal information to companies that process personal information on our behalf for a business or commercial purpose, including, but not limited to, website hosting, app design, database management, web analytics, app analytics, billing, payment processing, and communicating with you about our products or services (“Service Providers”).Service Providers are not permitted to sell or share your personal information or to use your personal information other than to perform the tasks we assign to them.

Third Parties
We do not disclose personal information to entities that may sell, retain, use, or disclose personal information for purposes beyond providing services directly to us for our business or commercial purposes.

Marketing and Advertising.
We may work with third party advertising and marketing companies (“Advertising Partners”) to provide you with advertisements, marketing, or other information that we think may interest you. These Advertising Partners may set or access their own cookies, pixels, tags, or similar technologies on our website and apps or they may collect or have access to data about you that was collected over time and across different online services. These Advertising Partners may also provide us with their own independent data about potential customers. Such data could include data about you that was previously collected by the Advertising Partner.

Compliance with Laws
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose your personal information to government or law enforcement officials or private parties in response to lawful requests when we believe disclosure or sharing is necessary to comply with any legal obligation, enforce or apply our terms and conditions, respond to claims and legal process, protect our services, members, dealers, our rights and/or the safety of the public or any person, or prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).

Sale or Transfer of Business or Assets
We may disclose some or all of your personal information in connection with a merger, bankruptcy, or other transaction in which another entity assumes control of all or part of our business. If another company or individual acquires our business, or assets, that company or individual will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Third parties, including Google and Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. You can opt-out of the collection and use of information for ad targeting using the options described in the Opting Out section below. The tracking technologies we may utilize include the following:

Cookies
We may use different types of cookies when providing different types of web-related services. If you do not know what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance. Cookies allow us to identify and authenticate visitors, track aggregate behavior, and enable important service features. We use both session ID cookies and persistent cookies. Session ID cookies are used to maintain your browser state as you browse through services, and they expire when you close your browser. A persistent Cookie remains on your hard drive for an extended period, and we use that to identify you should you return to services and want to find information you had previously entered or accessed. We may also contract with analytics services, third-party affiliate services, and third-party advertising companies to collect similar information. These cookies allow the ad servers to recognize your computer each time they send you an online advertisement, and compile information about you or others who use your computer. This information allows such advertising networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

You may disable cookies through your web browser. For information about opting out of these collection services, please see the Your Choices section below.

Web Beacons/Tags
We may automatically collect aggregate anonymous information through files embedded in our services and emails known as “web beacons.” We may deliver a web beacon to you through our services from an advertising network with which we have contracted. Web beacons allow third parties to provide anonymized and aggregated auditing, research, and reporting for us. Web beacons also allow us to tell whether email recipients are able to properly view messages or if email messages have been opened, to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to users. We do not tie the information gathered by web beacons to personal information.

Flash LSOs
When we post videos, third parties may use local shared objects, known as “Flash cookies,” to store your preferences for volume control or to personalize certain video features. Flash cookies are different from browser cookies because of the amount and type of data and how the data is stored. The cookie management tools provided by many popular browsers will not remove Flash cookies. To learn how to manage Flash cookie privacy and storage settings, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

Analytics
We may use analytics tools or similar tools provided by third parties (“Data Analytics Providers”) to help analyze how you and other users utilize our services. Analytics tools use cookies and other tracking technologies to collect information such as how often users visit our website, what pages they visit, and what other websites they have used prior to visiting our website. We use the information we get from analytics tools only to improve services. Analytics tools collect the IP address or other unique identifier assigned to you on the date you visited services. Analytics tools provided by third parties plant a persistent cookie on your web browser to identify you as a unique user the next time you visit our website, and the treatment of that information is governed by the third party’s terms of use and/or privacy policy. To learn about how Google uses data related to website analytics when you use our site or apps, click here: https://policies.google.com/technologies/partner-sites. For information about how Facebook uses cookies and other storage technologies, click here: https://www.facebook.com/policies/cookies/.

BY USING OUR WEBSITE AND TEXT MESSAGING SERVICES, YOU GIVE CONSENT FOR US TO SHARE YOUR DATA WITH THESE PROCESSORS, AND FOR THEM TO TRANSFER THIS INFORMATION ONWARD TO THEIR PARTNERS IN CONNECTION WITH PROVIDING OUR SERVICES TO YOU.

OPTING OUT
You can make the following choices regarding your personal information:

Promotional and Other Emails
You may choose, during the account registration processes on one of our websites, or otherwise, to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other materials related to our services. You can stop receiving these emails by sending a request to the email address in the Contact Us section below. If you decide not to receive these emails, we may still send you communications related to your current or former membership.

Behavioral Advertising
We may share your personal information with Advertising Partners, so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our website, or on other websites not operated by us. If you do not want third parties to collect information about your use of our services, you can opt-out of such at the Digital Advertising Alliance in the US.

PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

Analytics
Many analytics providers allow end-users to opt out of the retention of their information, including our third-party analytics providers. Please note that, typically, unless you create an account with the analytics provider, your choice to opt out applies only to the device from which you make the request, because the providers use cookies on that device to recognize your choice. If you get a new device, install a new web browser, update your browser, or otherwise erase/alter your browser cookie files, you may clear the opt-out cookie.

You may learn more about the use of information by and opting-out of analytics from our third-party provider by visiting its opt-out page at the following links: www.google.com/policies/privacy/partners/ and https://tools.google.com/dlpage/gaoptout.

Cookies
You may disable, or delete cookies in your Web browser, but doing so may impact the usability of the website. To block cookies, you can also browse our service using your browser’s anonymous usage setting (called “Incognito” in Chrome, “In Private” for Internet Explorer, “Private Browsing” in Firefox and Safari, etc.).

INFORMATION SECURITY
We make efforts to protect your personal information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. All Personal Information submitted to or collected by us is hosted on secure servers both within our network and our partners providing extended services on premise and in the cloud. We use various physical, electronic, and procedural measures designed to protect your personal data from unauthorized access, disclosure, or misuse. We use strong encryption when transmitting your personal data.

We do not store your credit card information. All credit card information is transmitted on a PCI-compliant channel from a Verifone/Ingenico device to an encrypted tunnel.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have questions about the security of your personal information, contact us at the email or regular mail address specified in the Contact Us section below.

DATA RETENTION
We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.

THIRD-PARTY LINKS
Our websites or apps may contain links to other websites or apps. We are not responsible for the privacy practices or the content of these other websites or apps. You should read the policy statement of these other websites or apps to understand their policies. When you access linked websites or apps, you may be disclosing private information. It is your responsibility to keep such information private and confidential.

CHANGES TO THIS PRIVACY POLICY
We may update this Policy from time to time, in our sole discretion. When we do so, we will post the new Policy on our website. You should consult this Policy regularly for any changes. Continued use of services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.

CONTACT US
If you have questions regarding this Policy, its appendices, or our treatment of your personal information, you may contact us at:

(941) 955-9856

service@mortonsmarket.com