Privacy Policy

This Privacy Policy applies to Glanbia Inc. entities that focus on providing business-to-business services (collectively, “Glanbia Nutritionals,” “we,” “us,” or “our”). The Privacy Policy describes how Glanbia Nutritionals collects, uses, shares, and protects personal information in variety of contexts. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

Information We Collect

Glanbia Nutritionals collect information about you in a variety of ways depending on how you interact with us, our websites and our services, including:

Directly from you when you provide it to us, such as when you sign up to receive communications from Glanbia Nutritionals, interact with us in the context of a business opportunity, or contact us by phone, email, or otherwise.
Automatically through the use of cookies, server logs, and other similar technologies when you interact with our websites and emails.
From other sources, including, for example, our affiliates, business partners, service providers, social media networks, your employer, and other third parties, or from publicly available sources.

The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.

Context	Types of Data	Primary Purpose for Collection and Use of Data
Client & Business Partner Contact Information	We collect the name, and contact information, of our clients and business partners, as well as their employees with whom we may interact.	We have a legitimate interest in contacting our clients and business partners and communicating with their representatives concerning normal business administration such as orders, projects, services, and billing.
Cookies and First-Party Tracking	We use cookies and clear GIFs on our websites. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. See our Cookie Policy for more information.	We have a legitimate interest in making our website operate efficiently.
Cookies and Third-Party Tracking	We may place tracking technology on our website that collects analytics, records how you interact with our website, or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide marketing tailored to your interests. That third party might also collect information over time and across different websites in order to serve advertisements on our website or other websites. See our Cookie Policy for more information.	Where required by law, we base the use of third-party cookies upon consent.
Demographic Information	We collect your demographic information such as your location, preferences and interests.	We have a legitimate interest in understanding our clients and potential clients and in providing tailored services to users.
Email Interconnectivity	If you receive email from us, we use certain tools to capture data related to when you open our message or click on any links or banners it contains.	We have a legitimate interest in understanding how you interact with our communications to you.
Facility Access Information	If you visit a Glanbia Nutritionals facility, we may collect certain information from you upon your visit. This may include your name, contact information, job title, employer, identification documents and other information about your visit.	We have a legitimate interest in identifying visitors and securing our facilities. In some jurisdictions we may be required by law, regulation, or governmental order to collect and retain information related to issues of public health and safety. In such cases, we collect this information to comply with our legal obligations.
Feedback/Support	If you provide us feedback or contact us for support we will collect your name and email address, as well as any other content that you send to us, in order to reply.	We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Mailing List	When you sign up for one of our mailing lists we collect your name, email address and company/employer name.	We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.
Surveys	When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.	We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.
Website Interactions	We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.	We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Web Logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.	We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

How We Use Information

In addition to the purposes and uses described above, we use information in the following ways:

To identify you when you visit our websites.
To administer our business relationships with our clients and business partners and their employees.
To improve our services and product offerings.
To conduct analytics.
To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
To send marketing and promotional materials including information relating to our products and services and those of our affiliates and business partners.
To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
To debug, identify and repair errors that impair existing intended functionality of our websites.
To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
For internal administrative purposes.
For such other purposes as you may consent (from time to time).

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.

To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.

How We Share Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, a Glanbia Nutritionals entity, its business, or its assets, we will also share information with that company, including at the negotiation stage.
Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
Other Disclosures with Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.

Your Choices

Some jurisdictions give you a right to make the following choices regarding your personal information:

Access To Your Personal Information. You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
Changes To Your Personal Information. We rely on you to update and correct your personal information. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
Deletion Of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
Opt-out of Targeted Advertising. You may opt-out of online tracking-based targeted advertising (e.g., cookies) by adjusting the cookie settings. Please note that if you change browsers or computers, or if you clear your browser’s cache, you may need to click the link again to apply your preference.
Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
Online Tracking. We do not currently recognize the “Do Not Track” signal.
Marketing Emails. You may choose to provide us with your email address for the purpose of allowing us to send newsletters and other marketing materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
Promotional Mailings. From time to time, we may send marketing mailers about our services. If at any time you do not want to receive marketing mailers from us you can remove yourself from our mailing lists by emailing us at the email address below with “no physical mail” in the subject line along with your name, address, and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
Revocation Of Consent. Where we process your personal information based upon consent, you may revoke consent. Please note, if you revoke your consent for the processing of personal information then we may no longer be able to provide you services.

Please note that not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.

Submitting Requests

You may exercise the rights described above by contacting us as indicated in the “Contact Information” section below.
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name and the date or context of your last interaction with us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to respond to your request.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a letter signed by the requestor indicating that you are able to act on another person’s behalf.

How We Protect and Retain 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 unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

We retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Transmission of Information to Other Countries

As a multi-national company, we transmit information between and among our affiliates. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you understand and agree that we may transfer, store, and process your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.

Third-Party Applications/Websites

For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.

Changes To This Privacy Policy

We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

Additional Information For California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Policy.

California Shine the Light. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the Contact Information section above.
Notice of Collection. California law requires certain businesses to disclose the categories of personal information they collect, disclose for a business purpose, “sell” and/or “share” (as those terms are defined by California law). While not all Glanbia Nutritional entities are subject to this requirement, we have provided the following table for your convenience to help you understand our sharing practices. Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” your personal information, nor do we “share” your information for the purpose of cross-context behavioral advertising without your consent. For details regarding how we use personal information, please see the Information We Collect section of the Privacy Policy. For information regarding how long we retain personal information, please refer to the How We Protect and Retain Information section of the Privacy Policy.

Category of Personal Information	Category of Recipients – Disclosures for a Business Purpose
Identifiers – including, for example, name, email address, postal address, unique personal identifier, online identifier, or other similar identifiers.	Advertising networks (with your consent) Affiliates or subsidiaries Business partners Data analytics providers Internet service providers Operating systems and platforms Other Service Providers Payment processors and financial institutions, for example, in connection with business opportunities) Professional services organizations, including, for example, auditors and law firms Social networks
Government Issued Identification – including, for example, driver’s license number, or state issued identification number, passport number.	Affiliates or subsidiaries Operating systems and platforms Other Service Providers Professional services organizations, including, for example, auditors and law firms
Financial Information – including, for example, company credit card number, debit card number, and other financial information.	Payment processors and financial institutions, for example, in connection with business opportunities) Other Service Providers Professional services organizations, including, for example, auditors and law firms.
Health Related Information – this may include medical information such as body temperature or COVID-19 status	Affiliates or subsidiaries Professional services organizations, including, for example, auditors and law firms
Commercial information – including, for example, information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Advertising networks (with your consent) Affiliates or subsidiaries Business partners Data analytics providers Internet service providers Operating systems and platforms Other Service Providers Payment processors and financial institutions, for example, in connection with business opportunities) Professional services organizations, including, for example, auditors and law firms Social networks
Biometric information – including, for example, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns, or rhythms, and sleep, health, or exercise data that contain identifying information	Service providers, including, for example vendors who manage our physical security systems for our facilities. Professional services organizations, including, for example, law firms
Internet or other electronic network activity information – including, for example, browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.	Affiliates or subsidiaries Business partners Data analytics providers Internet service providers Operating systems and platforms Other Service Providers Payment processors and financial institutions, for example, in connection with business opportunities) Professional services organizations, including, for example, auditors and law firms Social networks
Geolocation data	Advertising networks (with your consent) Affiliates or subsidiaries Business partners Data analytics providers Internet service providers Operating systems and platforms Other Service Providers
Audio, electronic, visual, thermal, olfactory, or similar information – including, for example CCTV footage from our facilities	Operating systems and platforms Other Service Providers Professional services organizations, including, for example, auditors and law firms
Professional or employment-related information	Affiliates or subsidiaries Business partners Operating systems and platforms Other Service Providers Professional services organizations, including, for example, auditors and law firms
Inferences drawn from any of the information listed above	Advertising networks (with your consent) Affiliates or subsidiaries Business partners Data analytics providers (with your consent) Internet service providers Operating systems and platforms Other Service Providers Payment processors and financial institutions, for example, in connection with business opportunities) Professional services organizations, including, for example, auditors and law firms Social networks
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – including, for example, signatures	Affiliates or subsidiaries Other Service Providers Professional services organizations, including, for example, auditors and law firms

California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined under California law): health information (e.g., covid status or similar information), biometric information. This information is collected in order to manage the security and safety of our facilities, comply with applicable laws, or manage our business. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.

Contact Information

Glanbia Nutritionals includes the following entities: Glanbia Nutritionals, Inc., Glanbia Nutritionals (NA), Inc., Glanbia Business Services, Inc., Glanbia Nutritionals Services, LLC, Glanbia Foods, Inc., Aseptic Solutions USA Ventures, LLC, Southwest Cheese Company, LLC, MWC (Michigan), LLC, Pacmoore Process Technologies, LLC, Foodarom USA, Inc. and Sterling Technology, LLC. If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

gnprivacy@glanbia.com
1-833-GLANBIA (452-6242).

If you are asked to leave a message, please note that the question relates to the Workplace Privacy Policy.

If you are not satisfied with our response, and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.

Effective Date: May 10, 2023
Last Update: May 10, 2023