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THE DATA WE COLLECT, HOW IT'S USED, AND WHO WE SHARE IT WITH



We care about your privacy and want to help you understand how we collect, use,
and share your personal information.



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GOPUFF PRIVACY NOTICE

PRIVACY NOTICE / YOUR PRIVACY RIGHTS
1. Introduction
2. Sources of Personal Information
3. Types of Personal Information We Collect
4. How We Use Your Personal Information
5. With Whom We Share Your Personal Information
6. How We Use Cookies and Automatic Data Collection Tools
7. Security and Retention
8. Children's Privacy
9. External Links
10. Terms of Use
11. Contact Info
12. Your California Privacy Rights
13. Supplemental information for the EEA, Switzerland and the UK


SMS TERMS OF SERVICE

Gopuff Short Code Terms of Service


BEVMO! PRIVACY NOTICE

BevMo! Privacy Notice



WE'RE TAKING A DIFFERENT APPROACH TO PRIVACY

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GOPUFF PRIVACY NOTICE


EFFECTIVE DATE:SEPTEMBER 1, 2021


PRIVACY NOTICE / YOUR PRIVACY RIGHTS

If you are a California resident, refer to section 12 for more information about
your specific privacy rights.

If you are a resident of the European Economic Area (“EEA”, including European
Union Member States, Iceland, Liechtenstein and Norway), Switzerland, or the UK,
refer to section 13 for more information about your specific privacy rights.


1. INTRODUCTION

The GoBrands Inc. group of companies (operating as “Gopuff”), including all of
its affiliated companies (“us,” “we,” or “our”) collects and processes
information about you as described in this Privacy Notice (“Notice”). We are
committed to protecting your privacy. This Notice contains details about how we
collect, use, and share Personal Information that we obtain from and about you
when you interact with us on our website, via our mobile app, via email, and
through other online and offline interactions. Please read this Notice
carefully.

Applicability: We collect information regarding the following current, past, and
prospective categories of individuals:

 * customers and users of our websites, mobile apps and other online content on
   which this Notice is displayed;
 * independent contractors, including independent delivery drivers (“Driver
   Partners”) (unless a Driver Partner is considered an employee, in which case
   a separate employee privacy notice will apply);
 * representatives and employees of suppliers and other business partners; and
 * current, past, and prospective job applicants.

We may provide further supplemental notices, as appropriate.

This Notice does not apply to the following information:

 * Information about our employees and certain contractors and agents acting in
   similar roles. Such information is subject to a separate privacy notice that
   we will make available to those individuals.
 * Health or medical information. Such information is subject to a separate
   privacy notice that we will make available when relevant.
 * In the United States, information we collect from individuals with whom we
   engage in solely business-to-business communications and transactions, such
   as information about the employees of our business partners and customers.

Changes: We may update this Notice from time-to-time. The current Notice will be
effective as of the Effective Date set forth above. Please check this Notice
periodically for updates. If any of the changes are unacceptable to you, you
should cease interacting with us. When required under applicable law, we will
notify you of any changes to this Notice. When required under applicable law
(and excluding the EEA, Switzerland, and the UK) , we will seek affirmative
consent from you before making material changes to the way we handle Personal
Information previously collected from you. If you do not provide such consent,
Personal Information will continue to be used in a manner that is consistent
with the version of this Notice under which it was collected.


2. SOURCES OF PERSONAL INFORMATION

“Personal Information” or “Personal Data” refers to any information relating to
an identified or identifiable natural person or household.

We collect information about you and how you interact with us in several ways,
including:

 * Information you provide to us directly. We collect information you provide to
   us directly. This includes when you register and communicate with us directly
   through our websites or mobile apps or other instances as described below.
 * When you apply for a job with us. We collect Personal Information directly
   from prospective employees, independent consultants, advisers and other
   prospective staff who submit applications for our consideration (e.g. via a
   dedicated, online talent management platform or via email communication). We
   may also receive Personal Information about job applicants from third parties
   who provide services to us, including but not limited to staffing or
   recruiting firms, internal or external referrals, and from other third
   parties who provide additional background information to us (i.e. references,
   background checks, etc).
 * Information collected when you drive for us. We collect information about you
   through our Driver Partner app, including your location while delivering and
   other information about your services to us.
 * Information collected/received when you/your company do business with us. We
   may collect and process Personal Information concerning representatives (e.g.
   employees) of our current, past, and prospective customers, suppliers,
   investors and business partners that such individuals or their company (e.g.,
   acting as your employer) provide to us.
 * Information automatically collected or inferred from your interaction with
   us. We automatically collect technical information about your interactions
   with us when you use our websites and mobile apps (such as IP address,
   browsing preferences, and cart and purchase history.)
 * Information from public sources, including government entities from which
   public records are obtained and information you submit in public forums.
 * Information from other third parties. We receive information about you and
   your interactions with us from third parties, such as from your friends or
   family, third party service and content providers, entities with whom we
   partner to sell products, telephone and fax companies, social media networks,
   data brokers, and others interacting with us.

We may combine information that we receive from the various sources described in
this Notice, including third party sources and public sources, and use or
disclose it for the purposes identified below.


3. TYPES OF PERSONAL INFORMATION WE COLLECT

The types of information that we have collected about you during the previous 12
months are:

 * Identifiers, such as your name, alias, postal address, country of residence,
   unique personal identifier, online identifiers (such as various advertising
   identifiers), internet protocol (IP) address, email address, account name,
   phone number, social media identifiers (e.g., Twitter handle, Instagram name,
   etc.), driver’s license number, passport number, or other similar
   identifiers.
 * Customer Records, such as signatures and ID cards (presented to our drivers
   in instances where this is required for delivery of age-sensitive products,
   such as alcohol or tobacco).
 * Protected Class and Demographic Information, such as age, race (only where
   authorized under applicable local laws), gender, national origin, sex,
   disability (where allowed under local laws), citizenship, military or veteran
   status, education, or date of birth.
 * Financial Information, such as a bank account number for us to be able to
   charge for goods and services, and pay our Driver Partners and other
   contractors. We do not store your full credit/debit card numbers, as these
   are stored by our payment services/gate provider. We only store a tokenized
   ID of the last four digits of your card, expiration date and type.
 * Health or Medical Information, when your order contains prescription
   medication.
 * Commercial Information and Preferences, including records of personal
   property, creditworthiness, products or services purchased, obtained, or
   considered, or other purchasing or consuming histories or tendencies.
 * Internet or Other Electronic Network Activity and Device Information, such as
   your browsing history, search history, and information regarding your
   interactions with us (through our website and mobile apps, or through
   advertisements on third party platforms), and operating system/platform of
   your device.
 * Geolocation Information, such as longitude and latitude from your IP address
   or mobile device location. If you are our customer, we collect this when you
   submit your address at the time of order (if you enabled location sharing for
   our mobile app). If you are our driver, we collect this information while you
   are delivering the order.
 * Audio, Electronic, Visual, Thermal, Olfactory or Similar Information, such as
   full-face photographic images (when you apply for a job, sign-up as a user /
   driver or where we check your identity for delivery of age-sensitive
   products), video recordings / photos of our premises, call center recordings,
   or customer support chat logs.
 * Professional, Employment, or Education Information, such as job title,
   business address, employment history, or other professional information. This
   may also include information about your previous work performance provided by
   your former employers or other references provided by third parties and
   information regarding your right to work in the country, where the position
   for which you are applying is located (this may include citizenship/residency
   data, passport data, visa data, and work permit details).
 * Education Information, such as your education history, qualifications and
   certifications you hold, and other information that is not publicly available
   personally identifiable information as defined in the Family Educational
   Rights and Privacy Act.
 * Inferences drawn from any of the information we collect to create a profile
   about you reflecting your preferences, characteristics, psychological trends,
   predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


4. HOW WE USE YOUR PERSONAL INFORMATION

We may use each category of your information described above in the following
ways:

 * To enable interactions between you and us and to provide our services to you,
   such as to facilitate online purchases of our products; process shipping,
   returns, and related location tracking (which is active only while our
   customer enters their address in our platform to order); register and
   administer your account, provide you with and support your interactions with
   us; diagnose, repair and track service and quality issues; facilitate an
   order, download, return, or exchange; provide requested product information;
   communicate with you about your account or our data practices; install and
   configure changes and updates to programs and technologies related to
   interactions with us; authenticate those who interact with us; or to respond
   to your requests, complaints, and inquiries.
 * To facilitate subscription programs, such as our FAM monthly/yearly
   subscription program to deliver to you the benefits associated with these
   programs when you fulfil the conditions outlined therein (and to verify you
   have done so), such as reduced delivery fees and other offers, as applicable
   from time-to-me.
 * Facilitate business relationship with you/companies, acting as our investors,
   suppliers and other business partners, such as to enter into contracts,
   provide you with updates as required under applicable laws and/or agreements
   with you, to coordinate sales orders and management, warranty management,
   credit and payment collection, compliance with relevant export control,
   anti-money laundering, accounting and other business-based legal requirements
   that require us to process your Personal Information. 
 * Talent recruitment, including to process and evaluate your application for a
   position with us. We will carry out an initial screening of applications
   received and may choose to proceed to additional assessment rounds with some
   of the candidates where further information may be required. We will provide
   successful candidates with a dedicated notice for employees, as appropriate.
 * Driver Partner management, including to enter into agreements with you,
   ensure appropriate remuneration by collecting data about orders you have
   fulfilled through the driver app, to track your location in the course of
   delivery, assign deliveries to you, and manage any communications between us.
 * For our own internal business-improvement purposes, such as to evaluate or
   audit the usage and performance of programs and technologies related to
   interactions with us, including crash reporting; evaluate and improve the
   quality of your interactions with us and programs and technologies related to
   interactions with us; design new services; process and catalog your responses
   to surveys or questionnaires (e.g., customer satisfaction reviews); perform
   internal research for technological development and demonstration; conduct
   data analysis and testing; maintain proper business records and other
   relevant records.
 * Surveys and questionnaires. We may ask you to complete an online survey,
   opinion poll or other questionnaire in order to obtain your input on our
   services or relationship, which will help us improve our business practices.
 * For legal, safety, or security reasons, such as to comply with legal
   requirements; establish, exercise or defend against legal claims that we may
   have against you/pursue together with you, whether in court proceedings or in
   an administrative or out-of-court procedure; protect our safety, our property
   or rights of those who interact with us, or others; and detect, prevent, and
   respond to security incidents or other malicious, deceptive, fraudulent, or
   illegal activity.
 * In a de-identified, anonymized, or aggregated format. Depending on the
   applicable law, when converted to a de-identified, anonymized, or aggregated
   format, data may no longer constitute Personal Information and we may use
   this information for any purpose, as legally permitted.
 * For marketing. We may use your Personal Information to market our products or
   services or those of third parties, such as our business partners. We may use
   your Personal Information when you participate in marketing surveys,
   questionnaires, promotions, testimonials, online comments, product feedback,
   events, sweepstakes or other contests. We may audit aspects of our ad
   impressions. We may use your Personal Information for short-term transient
   use, including for contextual ad customization. We may use your Personal
   Information to enhance our content and to potentially send you commercial
   emails or other digital or voice communications.
   To opt-out of receiving promotional email messages or other digital or voice
   communications from us, please click on the "Unsubscribe" link contained at
   the bottom of the communication or by contacting us using the information in
   section 11 below.
   Some of our marketing materials and information may use tracking technologies
   and analytics tools to help us understand your preferences. For further
   information, please see Section 6.
 * Corporate transactions. We may use your Personal Information in order to
   comply with requests of a prospective or an actual purchaser interested in
   our companies and other assets, or in relation to a prospective or actual
   purchase of companies or assets by us.
 * For any other purposes for which you provide consent. 


5. WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

We may share your Personal Information with the categories of recipients
described below:

 * Affiliates and subsidiaries: We may share your Personal Information within
   our group of companies, which includes parents, corporate affiliates,
   subsidiaries, business units and other companies that share common ownership
   for the purposes described above.
 * Service providers: We may share your Personal Information with service
   providers working on our behalf in order to facilitate our interactions with
   you or request or support our relationship with you, such as hosting service
   providers, IT providers, operating systems and platforms, internet service
   providers, data analytics companies, and marketing providers (e.g., we may
   share your email address with our outbound email marketing provider). We may
   contract with other companies to provide certain services, such as identity
   verification, email distribution, market research, promotions management and
   payment processing. We provide these companies with only the information they
   need to perform their services and work with them to ensure that your privacy
   is respected and protected. These companies are prohibited by contract from
   using this information for their own marketing purposes or from sharing this
   information with anyone other than with us, unless at our direction as part
   of providing the service or with your agreement.
 * Business partners: We may also provide your Personal Information or provide
   access to your Personal Information to our vendors and other business
   partners, such as shipping companies, brand partners, marketing and
   advertising companies, and our investors.
 * Fulfillment partners: We may provide your Personal Information or provide
   access to your Personal Information to entities that assist us in fulfilling
   your orders, such as local alcohol stores from which that portion of your
   order is obtained. 
 * Professional advisors: We may share your Personal Information with various
   professional advisors such as recruitment agencies/professionals and lawyers,
   accountants, auditors, translators and where they advise us on our
   relationship.
 * For legal, security and safety purposes: We may share your Personal
   Information with third parties such as law enforcement or other government
   agencies and authorities and courts to comply with law or legal requirements;
   to enforce or apply our Terms of Use and other agreements; and to protect our
   rights and our property or safety of our users or third parties; or to
   otherwise establish, exercise and defend against legal claims (including by
   sharing data with opposing or other related parties to the proceedings and
   their professional advisors).
   If you are a law enforcement officer or government agency seeking information
   and have a valid subpoena or fraud affidavit please submit it here.
 * In connection with a corporate transaction: If we sell/acquire some or all of
   our assets, merge or are acquired by another entity, including through a sale
   or in connection with a bankruptcy, we will share your Personal Information
   with that entity.
 * The public: There may be opportunities for you to make public comments
   regarding us or our products. If you provide testimonials we will post your
   name along with the testimonial with your consent. If you provide feedback we
   will post your name along with the feedback with your consent. We may post
   anonymized testimonials and content feedback without your consent. Any
   Personal Information in posted testimonials or feedback, and any comments you
   otherwise post on a blog or forum, may be read, collected, or used by other
   users or the public.
 * With any entity to which you consent to us sharing your Personal
   Information. 

We may also de-identity, anonymize, or aggregate Personal Information to share
with third parties for any purpose, as legally permitted.


6. HOW WE USE COOKIES AND AUTOMATIC DATA COLLECTION TOOLS

We also collect information, via cookies, web beacons, pixels, tags or other
tracking technologies, such as your Internet Service Provider and IP address,
the date and time you access our website or mobile app, the pages you accessed
while visiting our website or mobile app, and the Internet address from which
you accessed our website or mobile app. Some cookies exist only during a single
session and some are persistent over multiple sessions over time. We and our
partners use these technologies to ensure basic functionality of our website and
mobile app, to remember user preferences (including regarding your preferences
regarding tracking technologies), maximize the performance of our website,
mobile app, and services, provide you with offers that may be of interest to
you, measure the effectiveness of our website, mobile app, and email campaigns
and to personalize online content. These cookies and other technologies may be
used to track you over time and across devices. When required by law, we only
use these tracking technologies, when you have given us your consent to do so.

To provide you with a more relevant and interesting experience, we may work with
third party companies to display ads or customize the content on our website or
mobile app. These companies may use cookies and similar tracking technologies as
described in this Notice to gather information about your visits to the website
or mobile app, as well as your visits elsewhere on the Internet. These companies
also may use this information to provide you with more relevant advertising
known as interest-based advertising. For more information about third-party
advertisers and how to prevent them from using your information, please visit
https://www.networkadvertising.org/choices/. This is a site offered by the
Network Advertising Initiative ("NAI") that includes information on how
consumers can opt-out from receiving interest-based advertising from some or all
of NAI's members. The Digital Advertising Alliance (“DAA”) also offers a choice
mechanism with respect to certain types of data collection and use by third
parties available at www.aboutads.info. Opting out of interest-based advertising
will not opt you out of all advertising, but rather only interest-based
advertising from us or our agents or representatives. Similarly, asking our
mobile apps not to track you/not agreeing or rejecting tracking technologies in
our cookie banner/preference center/mobile app selection screen will only opt
you out of those technologies, but not all advertising. Some browsers have
incorporated Do Not Track (“DNT”) preferences. Most of these features, when
turned on, send signals to the website you are visiting that you do not wish to
have information about your online searching and browsing activities collected
and used. As there is not yet a common agreement about how to interpret DNT
signals, we do not honor DNT signals from website browsers at this time.
However, you may not accept to/refuse or delete cookies. If you do not
accept/refuse or delete cookies, some of our website functionality may be
impaired or some of the advertising served to you may not be relevant for you
anymore. If you change computers, devices, or browsers, or use multiple
computers, devices, or browsers, and delete your cookies, you may need to repeat
this process for each computer, device, or browser. Please refer to your
browser’s Help instructions to learn more about how to manage cookies and the
use of other tracking technologies. You can also find more information on
managing cookies at All About Cookies - Manage Cookies.

Our websites use Google Analytics, a web analysis service provided by Google
Inc. (“Google”). Google Analytics cookies collect your IP address; however,
because IP anonymization is used on this website, your IP address will be
shortened (and therefore anonymized) as soon as technically possible and before
it is stored or otherwise used in connection with Google Analytics. The
anonymization process takes place within the European Union or the European
Economic Area, except in exceptional cases, where your full IP address may be
sent to a Google server in the United States and shortened there. We use the
information collected by Google Analytics cookies to find out about how visitors
use our website, to throttle request speed and for advertising tracking. Google
will not combine the IP address sent by your browser in connection with Google
Analytics with other data. You can prevent Google Analytics cookies from being
stored by setting your browser software accordingly or opting-out of Google
Analytics by downloading and installing the browser plug-in available here:
https://tools.google.com/dlpage/gaoptout. You can also change settings regarding
which cookies and tracking technologies placed on your device you allow us and
our partners to read, in our cookie preference center. Changing these settings
will not delete these cookies, but we will no longer be able to utilize them for
the purposes you decided to turn off.


7. SECURITY AND RETENTION

We maintain reasonable security procedures and technical and organizational
measures to protect your Personal Information against accidental or unlawful
destruction, loss, disclosure, alteration, or use.

Your Personal Information will be retained as long as necessary to fulfil the
purposes we have outlined in Section 4. of this Notice, unless we are required
to do so by applicable law.

This includes retaining your data to provide you with the services requested and
interact with you; maintain business relationship with you/your company;
determine eligibility of candidates, prepare for future contract establishment
and keep data to account for future job offers; to manage relationship with our
drivers; to improve our business over time; to ensure ongoing legality, safety
and security of our services and relationships or otherwise in accordance with
our internal retention procedures. Once you / your company has terminated the
contractual relationship with us or otherwise ended your relationship with us,
we may retain your Personal Information in our systems and records in order to
ensure adequate fulfillment of surviving provisions in terminated contracts, or
for other legitimate business purposes, such as in order to enable easier future
user onboarding, in order to evidence our business practices and contractual
obligations, or to provide you with information about our products and services
in case interest.

If you would like to know more about retention periods applicable to your
particular circumstance, you can contact us using details provided in section 9
below.


8. CHILDREN'S PRIVACY

Interactions with us are intended for individuals 16 years of age and older. Our
interactions are not directed at, marketed to, nor intended for, children under
16 years of age. We do not knowingly collect any information, including Personal
Information, from children under 16 years of age. If you believe that we have
inadvertently collected Personal Information from a child under the age of 16,
please contact us at the address below and we will use reasonable efforts to
delete the child’s information from our databases.


9. EXTERNAL LINKS

When interacting with us you may encounter links to external sites or other
online services, including those embedded in third party advertisements or
sponsor information, that we do not control. We are not responsible for their
privacy practices and data collection policies for such third party services.
You should consult the privacy statements of those third party services for
details.


10. TERMS OF USE

The End-User License and Terms of Service for interactions with us can be found
on your country-specific Gopuff website.


11. CONTACT INFO

If you have questions regarding this Notice, please contact us at:
dpo@gopuff.com.


12. YOUR CALIFORNIA PRIVACY RIGHTS

This section applies to certain California residents and supplements the rest of
our Notice above. This section does not apply to the following information:

 * Information about individuals who are not California residents;
 * Information about our own employees, contractors, agents, and job applicants.
   Such information is subject to a separate privacy notice that we will make
   available to individuals.
 * Information we collect from individuals with whom we engage in solely
   business-to-business communications and transactions, such as information
   about the employees of our business partners and customers;

Pursuant to the California Consumer Privacy Act of 2018, below is a summary of
the Personal Information we collected from consumers, the sources from which we
collected the Personal Information, the business or commercial purpose for which
the Personal Information was collected and the categories of third parties with
whom we share consumer Personal Information. The section references relate to
the sections above in this Notice.

Source of Your Personal Information

The categories of sources of personal information are detailed in Section 2
above and are summarized as follows: (a) directly from you, (b) through
automated technologies or interactions, (c) public sources, and (d) from third
parties.

Uses of Your Personal Information

The business and commercial purposes for which we collect personal information
are detailed in Section 4 above and include purposes, such as : (a) performing
services, (b) auditing, (c) legal and compliance, (d) quality assurance, (e)
security, (f) debugging, (g) short term, transient use, (h) internal research,
(i) corporate transactions, and (j) marketing.

Sharing Personal Information

Our data sharing practices are detailed in the chart below and align with the
information provided above in Section 3 (Personal Information), Section 5
(Sharing), and Section 6 (How We Use Cookies and Automatic Data Collection
Tools).

Categories of Personal
Information We Collect

Categories of Third Parties With Whom We Disclose Personal Information for a
Business Purpose

Categories of Third Parties To Whom We Sell Personal Information

Identifiers such as real name, postal address, country of origin, IP address,
email address, account name, date of birth, other similar identifiers.

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6 described in Section 6
 * Entities to which you have consented to the disclosure

Personal information subject to the California Customer Records Act, such as
signatures.

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

 * Business partners
 * Fulfilment partners
 * Entities to which you have consented to the disclosure

Characteristics of protected classifications under California or Federal Law,
such as age and gender.

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Entities to which you have consented to the disclosure

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Commercial information, including products or services purchased, obtained or
considered, or other purchasing or consumer history.

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Internet or other electronic network activity information, including, but not
limited to, status/HTTP status code, operating system and its interface, version
of browsing software, device ID, other device information, browsing history,
search history and information regarding a consumer’s interaction with an
internet website, application or advertisement.

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Entities to which you have consented to the disclosure

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Geolocation data, such as your precise or approximate location derived from
information from your mobile device.

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Other audio, electronic, visual, thermal, olfactory, or similar information,
such as audio recordings of customer service calls.

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Inferences drawn from any of the information identified above to create a
profile about a consumer reflecting the consumer’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes.

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6

Categories of Personal
Information We Collect

Identifiers such as real name, postal address, country of origin, IP address,
email address, account name, date of birth, other similar identifiers.

Categories of Third Parties With Whom We Disclose Personal Information for a
Business Purpose

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

Categories of Third Parties To Whom We Sell Personal Information

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6 described in Section 6
 * Entities to which you have consented to the disclosure

Categories of Personal
Information We Collect

Personal information subject to the California Customer Records Act, such as
signatures.

Categories of Third Parties With Whom We Disclose Personal Information for a
Business Purpose

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

Categories of Third Parties To Whom We Sell Personal Information

 * Business partners
 * Fulfilment partners
 * Entities to which you have consented to the disclosure

Categories of Personal
Information We Collect

Characteristics of protected classifications under California or Federal Law,
such as age and gender.

Categories of Third Parties With Whom We Disclose Personal Information for a
Business Purpose

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Entities to which you have consented to the disclosure

Categories of Third Parties To Whom We Sell Personal Information

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Categories of Personal
Information We Collect

Commercial information, including products or services purchased, obtained or
considered, or other purchasing or consumer history.

Categories of Third Parties With Whom We Disclose Personal Information for a
Business Purpose

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

Categories of Third Parties To Whom We Sell Personal Information

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Categories of Personal
Information We Collect

Internet or other electronic network activity information, including, but not
limited to, status/HTTP status code, operating system and its interface, version
of browsing software, device ID, other device information, browsing history,
search history and information regarding a consumer’s interaction with an
internet website, application or advertisement.

Categories of Third Parties With Whom We Disclose Personal Information for a
Business Purpose

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Entities to which you have consented to the disclosure

Categories of Third Parties To Whom We Sell Personal Information

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Categories of Personal
Information We Collect

Geolocation data, such as your precise or approximate location derived from
information from your mobile device.

Categories of Third Parties With Whom We Disclose Personal Information for a
Business Purpose

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

Categories of Third Parties To Whom We Sell Personal Information

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Categories of Personal
Information We Collect

Other audio, electronic, visual, thermal, olfactory, or similar information,
such as audio recordings of customer service calls.

Categories of Third Parties With Whom We Disclose Personal Information for a
Business Purpose

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

Categories of Third Parties To Whom We Sell Personal Information

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6
 * Entities to which you have consented to the disclosure

Categories of Personal
Information We Collect

Inferences drawn from any of the information identified above to create a
profile about a consumer reflecting the consumer’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes.

Categories of Third Parties With Whom We Disclose Personal Information for a
Business Purpose

 * Affiliates and subsidiaries
 * Service providers
 * Business partners
 * Fulfilment partners
 * Providers of legal, security, and safety assistance and resources
 * Entities involved in a corporate transaction
 * Cookie and automatic data collection entities
 * Entities to which you have consented to the disclosure

Categories of Third Parties To Whom We Sell Personal Information

 * Business partners
 * Fulfilment partners
 * Companies that operate cookie and other online tracking technologies
   described in Section 6

To our knowledge, we do not sell Personal Information of anyone under 16 years
of age.

Your Rights

Subject to legal limitations, certain California residents may exercise the
following rights by our webform at legal.gopuff.com, by emailing us at
dpo@gopuff.com, or by calling 888-299-8177.

 * Right to Know. You have the right to request information about the categories
   of Personal Information we have collected about you, the categories of
   sources from which we collected the Personal Information, the purposes for
   collecting the Personal Information, the categories of third parties with
   whom we have shared your Personal Information, and the purpose for which we
   shared your Personal Information (“Categories Report”). You may also request
   information about the specific pieces of Personal Information we have
   collected about you (“Specific Pieces Report”).
 * Right to Delete. You have the right to request that we delete Personal
   Information that we have collected from you.
 * Right to Opt Out. You have the right to opt out of the sale of your Personal
   Information.

We will not discriminate against you, in any manner prohibited by applicable
law, for exercising these rights.

Verification: In order to exercise your rights, we will need to obtain
information to locate you in our records or verify your identity depending on
the nature of the request. If you are submitting a request on behalf of a
household, we will need to verify each member of the household in the manner set
forth above. For a Specific Pieces Report, we will request your name, email, and
phone number to verify your identity and seek a signed declaration, under
penalty of perjury, that you are who you say you are. For a Categories Report,
we will request name, email, and phone number to verify your identity. For a
Right to Delete request, we will request your name, email, and phone number to
verify your identity.

Authorized Agents: Authorized agents may exercise rights on behalf of consumers,
but we reserve the right to also verify the consumer directly as described
above. Authorized agents may use the webform legal.gopuff.com and upload
documentation demonstrating the agent has authority to exercise rights on the
consumer’s behalf. At a minimum, we will require evidence of the agent’s
identity, proof of registration with the California Secretary of State, and at
least one of the following evidencing proof of your legal authority to act on
the behalf of the individual consumer:

 * Written authorization signed by the Consumer; or
 * Certified copy of a Power of Attorney granted under Probate Code.

Timing: We will address Requests to Opt-out within 15 business days. We will
respond to Requests to Delete and Requests to Know within 45 calendar days,
unless we need more time in which case we will notify you and may take up to 90
calendar days total to respond to your request.

California Shine the Light: If you are a California resident, you may opt out of
sharing your Personal Information with third parties for the third parties’
direct marketing purposes. Please contact us at dpo@gopuff.com if you would like
to do so.


13. SUPPLEMENTAL INFORMATION FOR THE EEA, SWITZERLAND AND THE UK

The following terms supplement the Notice with respect to our processing of
European Economic Area (i.e., European Union Member States, Iceland,
Liechtenstein and Norway), Swiss and the UK Personal Data. To the extent
applicable, in the event of any conflict or inconsistency between the other
parts of the Notice and the terms of this Section 13., Section 13. shall govern
and prevail with regards to the processing of EEA, Swiss and UK Personal Data.

 * Data Controller
   * Customers - The GoBrands entity with which you have a primary relationship
     with (such as the entity that provides services to and accepts payment from
     you; the entity that has provided you with marketing and promotional
     materials and communications; the primary entity in the region where you
     access our website or mobile application); is the controller of Personal
     Data collected from individuals within the scope of this Notice. In the
     majority of cases, this will be GoBrands Euro Intermediate Holdings, SARL,
     6, Rue Eugene Ruppert, Luxembourg City, Luxembourg, unless we specifically
     inform you otherwise. 
   * Job Applicants - the relevant controller for your Personal Data is the
     GoBrands entity to which you have submitted your job application. 
   * Driver Partners - the relevant controller for your Personal Data is the
     GoBrands entity with which you have signed your contract. 
   * When there is more than one entity responsible for the processing, such as:
     when two GoBrands entities co-sign a business contract with your company;
     multiple GoBrands entities organize marketing campaign together; or when
     our EU HQ (GoBrands Euro Intermediate Holdings, SARL) helps local entities
     pick the right candidates for senior roles in the company; such entities
     are jointly responsible for the lawfulness of a specific processing
     activity (“Joint Controllers”). 
   * On some occasions, more than one GoBrands entity may process your Personal
     Data as independent controllers. If you have any questions about
     controllership, do not hesitate to contact us (see Section 9 for contact
     information).
 * Legal bases for processing 
   * We rely on the following legal grounds for the collection, processing, and
     use of your Personal Data:
     * The processing is necessary for the performance of a contract to which
       you are a party or to take steps at your request prior to entering into a
       contract. This includes instances when we need to enable interactions
       between you and us and to provide our services to you; as well as when we
       need to facilitate business relationship with you/companies acting as our
       investors, suppliers and other business partners; and in course of our
       talent recruitment process when we are negotiating with potential
       candidates; and when we conclude and fulfil our part of the contract with
       our drivers.
     * The processing is necessary for compliance with a legal or statutory
       obligation to which we are subject. This includes instances when we are
       required by various business laws to carry out various compliance checks
       (such as anti-money laundering) related to our customers, investors,
       suppliers, and other business partners. It may also include various local
       compliance obligations and licenses we have to comply with regarding the
       operation of our service, including engagement of our drivers. We will
       also process job applicant data if required by local laws to do so for
       purposes of fair hiring process.
     * The processing is necessary for the purposes of the legitimate interests
       pursued by us or by a third party. This includes instances where we
       process your Personal Data for our own internal business-improvement
       purposes, certain survey and questionnaires we may carry out, and our
       marketing activities (for example by sending you digital direct marketing
       related to similar products/services we have provided to you), unless
       consent is required under applicable laws. We may also provide some of
       the auxiliary support to our services based on our legitimate business
       interest to do so, even though we are not required to do so under our
       contracts, including through various digital communication and other
       tools we provide in the course of our business / service relationship
       with you. We rely on our legitimate interest also in the course of our
       talent recruitment process for our initial interviews with potential
       candidates.
     * Where you provided us with your consent to the processing of your data
       for one or more specific purposes. This includes digital direct marketing
       communications, were your consent is required by law (for example if we
       are collecting your data on behalf of a third party), where you give us
       consent with keeping your application for other future opportunities, if
       such consent is necessary (otherwise, we would rely on our legitimate
       interest to do so), or in other instances where we asked for your consent
       in order to collect and process your Personal Data (we will inform you at
       each such occasion).
     * The processing is necessary for the establishment, exercise or defence of
       legal claims, whether in court proceedings or in an administrative or
       out-of-court procedure;
     * The processing is necessary to carry out the obligations and exercising
       specific rights in the field of employment, social security and social
       protection law, where national employment laws regulate certain aspects
       of hiring procedures that require processing of sensitive Personal Data.
   * Your Data Protection Rights 
     * Under the conditions set by applicable data protection laws, you may
       exercise the following rights regarding your Personal Data:
       * Access. You have the right to obtain confirmation from us if Personal
         Data is being processed, and related information; and the right to
         obtain a copy of your Personal Data undergoing the processing.
       * Rectification. You have the right to request the rectification of
         inaccurate Personal Data and to have incomplete data completed.
       * Objection. You have the right to object to the processing of your
         Personal Data for compelling and legitimate reasons relating to your
         particular situation, except in cases where legal provisions expressly
         provide for that processing.
       * Portability. You may receive your Personal Data that you have provided
         to us, in a structured, commonly used and machine-readable format and
         have the right to transmit it to other data controllers without
         hindrance. This right only exists if the processing is based on your
         consent or a contract and the processing is carried out by automated
         means.
       * Restriction. You may request to restrict the processing of your
         Personal Data in certain cases.
       * Erasure. You may request to erase your Personal Data if (i) it is no
         longer necessary for the purposes for which we have collected it, (ii)
         you have withdrawn your consent and no other legal ground for the
         processing exists, (iii) you objected and no overriding legitimate
         grounds for the processing exist, (iv) the processing is unlawful, or
         erasure is required to comply with a legal obligation.
       * Right to lodge a complaint. You also have the right to lodge a
         complaint with a supervisory authority, in particular in the country of
         the EEA, Switzerland or the UK where you reside, or where the issue
         that is the subject of the complaint occurred.
       * Right to refuse or withdraw consent. In case we ask for your consent to
         processing, you are free to refuse to give consent and you can withdraw
         your consent at any time without any adverse negative consequences. The
         lawfulness of any processing of your Personal Data that occurred prior
         to the withdrawal of your consent will not be affected.
       * Automated decision-making. You also have the right not to be subject to
         a decision based solely on automated processing (you can do so by
         contacting us at the Contact Info above) and to be given more
         information about why any such decision was made by contacting us using
         the Contact Details above.
   * International Transfers of Personal Data 
     * Due to the global nature of our operations, some of the recipients
       mentioned in Section 5 of the Notice may be located in countries outside
       the EEA, Switzerland or the UK, which do not provide an adequate level of
       data protection as defined by data protection laws in the EEA,
       Switzerland and the UK. Certain third countries have been officially
       recognized by the EEA, Swiss and UK authorities as providing an adequate
       level of protection and no further safeguards are necessary. The below
       outlines how we protect your Personal Data when transferring it outside
       those countries.
     * Intra-Group Intra-group international transfers will be to countries
       where GoBrands entities have offices, in particular the United States of
       America. The transfer of your Personal Data outside the EEA, Switzerland
       and the UK takes place on the basis of our intra-group data transfer
       agreements, which are based on EU and UK standard contractual clauses, as
       applicable.
     * Third Parties Some of the third parties with whom we share Personal Data
       are also located outside the EEA, Switzerland or the UK in third
       countries, which do not provide an adequate level of data protection as
       defined by data protection laws in the EEA, Switzerland or the UK.
       Transfers to third parties located in such third countries take place
       using an acceptable data transfer mechanism, such as the EU/UK Standard
       Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct
       and Certifications, on the basis of permissible statutory derogations, or
       any other valid data transfer mechanism issued by the EEA, Swiss or UK
       authorities. Please reach out to us using the Contact Info above, if you
       want to receive further information or, where available, a copy of the
       relevant data transfer mechanism.
 * Data Protection Officer
   * Please find below contact details for our EU data protection officer. 
   * Att: GoBrands EU/UK Data Protection Officer 
   * Email Address: dpo@gopuff.com 

Our Approach to Privacy
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