PRIVACY POLICY

Last Updated: April 12, 2022

This Privacy Policy (“Privacy Policy”) describes how Trilliant Food & Nutrition, LLC and our subsidiaries and affiliates  (collectively, “Trilliant,” “us,” “we,” or “our“) collect, use and share your personal information in connection with  our websites at www.trilliantfood.com, www.victorallen.com, and any other websites we operate that link to this  Privacy Policy (collectively, the “Site”), our services, our social media profiles, our email communications, and our  related products, sales, marketing, or events (collectively, the “Platform“), and the choices that you have with  respect to your personal information.

We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect,  use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy  Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective  date of the latest version of our Privacy Policy at the top of this Privacy Policy. Your continued use of the Platform  following posting of changes constitutes your acceptance of such changes.

1. COLLECTION OF PERSONAL INFORMATION

1.1. Personal Information We Collect. The types of personal information we may collect depend on the products  and services you request from us. The following are categories (with non-exhaustive examples) of personal  information we may collect about you:

Categories

• Individual Identifiers and Demographic Information
  
  Examples:
  • Contact information, such as your name, address, phone number, and email address.
  • Demographic information, such as general location information like city, state and geographic  area.
• Commercial Information
  
  Examples:
  • Payment information, such as your payment method, credit or debit card number, and billing  address.
  • Profile and account information, such as your account name and password, subscriptions, order  history, reviews, and products you have purchased.
  • Communications, such as email messages, phone calls, social media interactions, and other  communications.
  • Preferences, such as your preferences for receiving marketing and other communications and  your product interests.
  • Customer service call recordings, such as recordings that may be collected when you contact our  customer service team.
• Internet or Network Activity
  
  Examples:
  • Device information, such as your computer or mobile device operating system type and version  number, manufacturer and model, browser type, screen resolution, IP address, unique  identifiers, the website you visited before browsing to our website, and general location  information such as city, state or geographic area.
  • Online activity information, such as pages or screens you viewed, how long you spent on a page  or screen, navigation paths between pages or screens, information about your activity on a page  or screen, access times, and duration of access.
• Inferences Drawn from Personal Information
  
  Examples:
  • Profiles reflecting your preferences and other characteristics, such as inferences regarding your  preferences when using the Platform and other characteristics about your interactions with us  that we may combine with other personal information we collect about you as described in this  Privacy Policy.

1.2. Sources of Personal Information. We obtain the categories of personal information listed above from the  following categories of sources:

• Personal Information You Provide. We collect personal information when you voluntarily submit it to  us. For example, we may collect or receive personal information when you create an account on the  Platform, sign up to receive our emails, purchase a product, enroll in a new subscription, participate  in our promotions, contests, or surveys, post a review, submit a request to our customer service  team, interact with us on social media, or otherwise.
• Automatically Collected Personal Information. We, our service providers, and our advertising  partners may automatically log information about you, your computer or mobile device, and your  activity over time on our Platform and other sites and online services, including the device  information and the online activity information described in the table above. Like many online  services, the Platform uses cookies and similar technologies to facilitate automatic data collection,  such as:
  • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the  visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling  functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Flash cookies, or locally-stored objects, which are used on websites for purposes similar to  cookies but allow storage of a larger amount of data.
  • Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was  viewed or clicked, typically to compile statistics about usage of websites and the success of  marketing campaigns.
• Personal Information Obtained from Third Parties. We may also receive personal information about  you from other third party sources. For example, we receive personal information from our business  and advertising partners, event sponsors, joint marketing partners, affiliates and related companies, social media sites, or companies that provide us with personal information to supplement what we  already know about our customers and clients or help us identify new customers. We may merge or  combine such personal information with the other types of personal information we collect about  you.
• Referrals. Users of the Platform may have the opportunity to refer colleagues, friends, or other  contacts to us and share their contact information with us. Please do not refer someone to us or  share their contact information with us unless you have their permission to do so.

2. USE OF PERSONAL INFORMATION

We may use your personal information for various purposes, including the uses below and as otherwise described  in this Privacy Policy or at the time of collection:

2.1. To Provide the Platform and Our Services. We may use your personal information to:

• provide you with the products, subscriptions, content, features, and services that you request; • set up, maintain, and monitor your account on the Platform;
• process your transactions and purchases;
• communicate with you about the Platform (including by sending announcements, updates, security  alerts, and support and administrative messages);
• understand your interests, personalize your experience on the Platform, and deliver information  about products and services relevant to your interests; and
• respond to your inquiries and requests for customer support, including to investigate and address  your concerns and monitor and improve our responses.

2.2. For Research and Development. We use personal information to understand and analyze the usage trends  and preferences of our users to make our Platform and other offerings better, diagnose technical issues, and  develop new features and functionality. As part of these activities, we may create aggregated, de-identified or  other anonymous data from personal information we collect. We make personal information into anonymous  data by removing information that makes the data personally identifiable to you. We may use this anonymous  data and share it with third parties for our lawful business purposes, including to analyze and improve the  Platform and promote our business.

2.3. For Marketing and Promotional Communications. We may send you Trilliant-related or other offers,  promotions, and marketing communications as permitted by law. You may opt-out of our marketing  communications as described in the “Opt-out of Marketing Communications” section below.

2.4. Advertising. We, our business partners, and our third party advertising partners may collect and use your  personal information for advertising purposes. We may contract with third-party advertising companies and  social media companies to help us advertise our services, identify potential customers, and display ads on our  Site and other sites, including through the use of interest-based advertising. These companies may use cookies  and similar technologies to collect information about you (including the device information and online activity  information described above) over time across our Platform and other sites and services or your interaction  with our emails, and use that information to serve ads that they think will interest you and/or use hashed  customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can  learn more about your choices for limiting interest-based advertising, in the “Advertising Choices” section  below.

2.5. For Compliance, Fraud Prevention, and Protection. We may use your personal information to: • comply with applicable laws, lawful requests, and legal process (such as to respond to requests from  government authorities);

• maintain the safety, security, and integrity of our Platform, products and services, business,  databases and other technology assets;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending  legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal  policies;
• enforce the terms and conditions that govern the Platform; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity,  including cyberattacks and identity theft.

3. SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy or as otherwise described at the time  of collection, we may share your personal information with the following categories of recipients:

3.1. Service Providers. We share personal information with third parties and individuals who perform functions on  our behalf or help us run our business and the Platform, such as service providers that help us perform email  services, website hosting, maintenance services, database management, web analytics, billing, payment  processing, marketing, and other purposes.

3.2. Related Companies. We may share your personal information with companies that are affiliated with us (that  is, that control, are controlled by, or are under common control with us) or may be affiliated with us in the  future for the purposes described in this Privacy Policy.

3.3. Other Users and the Public. Your personal information may be shared with other users and the public on the  Platform. The Platform may provide you with the opportunity to post or make available content, messages,  and other information to other users of the Platform or the public, such as when you submit a product review  or communicate with us on social media. We do not control how other users or third parties use any personal  information that you make available to them. Please be aware that any information you post publicly can be  cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance  to edit or remove it.

3.4. Business Transactions. If we sell all or part of its business or make a sale or transfer of assets or are otherwise  involved in a corporate divestiture, financing, merger, consolidation, acquisition, reorganization, sale, spin-off,  or other disposition of all or any portion of the business or assets of, or equity interests in, Trilliant or our  related companies (including, in connection with a bankruptcy or similar proceedings), we may transfer your  personal information to a third party as part of that transaction, including at the negotiation stage.

3.5. Legal Authorities and Others. We may disclose your personal information to law enforcement, government  authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law  or for the compliance, fraud prevention and protection purposes described above.

3.6. Advertising and Other Business Partners. We may share your personal information with third party  advertising or joint marketing partners, as well as our other business partners for the purposes described in  this Privacy Policy or at the time of collection.

3.7. Professional Advisors. We may disclose your personal information to our professional advisors, such as  lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they  render to us.

4. SECURITY OF PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use  reasonable efforts to protect your personal information from the risks presented by unauthorized access or  acquisition, we cannot guarantee the security of your personal information.

5. YOUR CHOICES

You can make the following choices with respect to your personal information.

5.1. Access or Update Your Personal Information. You may review and update certain account information by  logging into your account on the Platform.

5.2. Opt-out of Marketing Communications. You may opt out of marketing-related emails by following the opt out or unsubscribe instructions at the bottom of the email, or by contacting us at  SupportDesk@victorallen.com. You may continue to receive service-related and other non-marketing emails.

5.3. Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this,  follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change  your settings. If you do not accept cookies, however, you may not be able to use all functionality of the  Platform and our Site may not work properly. For more information about cookies, including how to see what  cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

We use Google Analytics to help us understand user activity and patterns on the Site. You can learn more  about these cookies here and about how Google protects your data here. You can prevent the use of Google  Analytics relating to your use of our Site by downloading and installing a browser plugin available here.

5.4. Advertising Choices. Some of our advertising partners are members of the Network Advertising Initiative (NAI)  and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital  Advertising Alliance (DAA). You can obtain more information about these companies’ information collection  practices and opt-out of receiving interest-based advertising from participating NAI and DAA members at  https://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at  optout.aboutads.info. You can also limit collection of your information for interest-based ads by blocking third  party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block  third party cookies. In addition, your mobile device settings may provide functionality to limit use of the  advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of  interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Some of the third party advertising companies we may work with offer their own opt-out options that you can  use to limit their use of your information for interest-based advertising. Please note that we also may work  with companies that offer their own opt-out mechanisms, such as Google  (https://adssettings.google.com/authenticated) and Facebook (https://www.facebook.com/about/ads), or do  not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you  may receive interest-based advertising from other companies.

5.5. Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services  that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do  Not Track,” please visit https://www.allaboutdnt.com.

5.6. Declining to Provide Information. We need to collect personal information to provide certain services. If you  do not provide the information requested, we may not be able to provide those services.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Trilliant is headquartered in the United States of America. If you are from a country outside of the United States of  America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide  personal information to us, please note that any personal information that you provide to us may be transferred to  the United States of America. By providing your personal information, where applicable law permits, you hereby  specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth  herein or in any applicable terms of service.

7. OTHER SITES AND SERVICES

Our Platform may contain links to websites, mobile applications or other online services operated by third parties.  When you click on a link to any other website, mobile application or online service, you will leave our Platform and  go to another site, and another entity may collect personal information or anonymous data from you. In addition,  our content may be included on other online services that are not associated with us. We have no control over, do  not review, and are not responsible for, these third party online services or for their content or actions. Other online  services follow different rules regarding the collection, use and sharing of your personal information. We encourage  you to read the privacy policies of other online services that you visit or use. The links to third party online services  are for your convenience and do not signify our endorsement of, or affiliation with, any third party or its services.

8. CHILDREN

Our Platform is not intended for use by minors under the age of 16. If we learn that we have collected personal  information of a minor under 16 without the consent of the child’s parent or guardian as required by law, we will  delete it as soon as possible. If you believe that we might have any personal information collected online from a  minor under 16, please contact us at SupportDesk@victorallen.com.

9. NOTICE FOR CALIFORNIA RESIDENTS

This section applies only to California residents. It describes how we collect, use and share personal information of  California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018  (“CCPA”), and their rights with respect to their personal information. For purposes of this section, “personal  information” has the meaning given in the CCPA but does not include information exempted from the scope of the  CCPA. In some cases we may provide a different privacy notice to certain categories of California residents, in which  case that notice will apply instead of this section.

9.1. Personal Information That We Collect, Use, and Disclose. We describe:

• the categories of personal information we may have collected about you in the preceding 12 months in the  section above called “Collection of Personal Information”;
• the categories of sources from which we collect your personal information in the section above called  “Sources of Personal Information”;
• the business and commercial purposes for which we collect this information in the section above called  “Use of Personal Information”; and
• the categories of third parties to whom we disclose this information in the section above called “Sharing of Personal Information”.

Trilliant must also disclose whether the following categories of personal information are disclosed for a “business  purpose” or “valuable consideration” as those terms are defined under the CCPA. The CCPA also calls this latter  category a “sale.” Note that while a category below may be marked, that does not necessarily mean that we have  personal information in that category about you.

In the preceding twelve months, we have disclosed the following categories of personal information in the manner  described:

Category Personal Information is Disclosed Personal Information is Disclosed for a Business Purpose for Valuable Consideration

 

A. Individual Identifiers and Demographic Information Yes Yes B. Commercial Information Yes No C. Internet or Network Activity Yes Yes D. Inferences Drawn from Personal Information Yes No 9.2. Your Rights as a California Resident.

The CCPA provides California with the rights listed below:

• Right to Access. You have the right to request that Trilliant disclose certain information to you about our  collection and use of your personal information over the past 12 months, including:
  • The categories of personal information we collected about you.
  • The categories of sources of the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information. o The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
• Right to Erase/Delete. You have the right to request that Trilliant delete any of your personal information  that we collected from you and retained, subject to certain exceptions.
• Right to Opt-Out of Sales. If we “sell” your personal information, you can opt-out.  • Right to Nondiscrimination. You are entitled to exercise the rights described above free from  discrimination in the form or legally prohibited increases in the price or decreases in the quality of our  products and services.

Please note, these rights are not absolute and in some cases we may not be able to respond your request, such as  when a legal exemption applies or if we are not able to verify your identity.

9.3. How to Exercise Your California Privacy Rights.

• Access and Deletion Rights. To exercise the access and deletion rights described above, please submit a  request to us and provide the information we request that is required to verify your request by:  o Emailing us at SupportDesk@victorallen.com, or
  • Calling us at 1-800-619-7063.
• Right to Opt-Out of the “Sale” of Personal Information. Under California law, some of the data we share  with our advertising partners may qualify as a “sale” as defined under the CCPA. To exercise your right to  opt-out of such “sale”, please:
  • Email us at SupportDesk@victorallen.com, or
  • Click here: Do Not Sell My Personal Information.

When exercising your rights or otherwise assisting you, we may need to request specific information from you to  help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any  person who is not entitled to receive it. We may also contact you to ask you for further information in relation to  your request to speed up our response.

You may also designate an authorized agent to make a request on your behalf. If you do so, we may require the  requester’s proof of identification, the authorized agent’s proof of identification, and any other information that we  may request in order to verify your request, including evidence of valid permission for the authorized agent to act  on your behalf.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However,  we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded,  repetitive, or excessive.

We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than  45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In  this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

10. CONTACTING US

You may contact us via email at SupportDesk@victorallen.com or by writing to us at the address below:

Trilliant Food & Nutrition, LLC
Attn: Privacy – Legal 1101 Moasis Dr. PO Box 307
Little Chute, WI 54140