PORTOFINOTUNA.COM PRIVACY POLICY/YOUR PRIVACY RIGHTS

Effective as of: September 24, 2025

Portofino (“Portofino” or “us” or “we” or “our”) owns and operates the PortofinoTuna.com website (“Site”).

This Privacy Policy (“Policy”) will tell you about our data collection and handling policies and practices on our Site, when you communicate with us on social media, over the phone or in writing, or when you interact with Portofino through other means (together with the Site, the “Services”), so you are informed about how we handle the personal information we collect from you. We hope that you enjoy our Site and other Services and will come back often to visit!

Who and what does this Policy apply to?

This Policy only covers the information you provide on or through our Site or that is otherwise collected about you through Portofino Services as identified above. This Policy does not apply to all information collected when you interact with us on other platforms or when you use third-party services. Other sites owned or controlled by Portofino also may have their own privacy policies that should be reviewed.

This Site is directed at U.S. citizens located within the United States. Portofino only knowingly collects information from individuals within the United States. If you use the Site outside of the United States, you do so at your own risk and you understand and agree that your personal information (as defined below) will be accessed, used and stored in the United States, which may not have the same level of privacy protections under applicable law as compared to where you may reside.

THIS SITE IS INTENDED ONLY FOR INDIVIDUALS OVER 18 YEARS OLD. IF YOU ARE UNDER 18, PLEASE DO NOT ACCESS OR USE THE SITE. Portofino only knowingly collects information, including personal information, from adults 18 years of age and older. This Site is not directed at, marketed to, nor intended for, children under 18 years of age. Portofino does not knowingly collect any information, including personal information, from children under 18 years of age. If Portofino learns that any information was provided to it through the Site by a child younger than 18 years of age, Portofino will immediately delete such information.

How will we tell you about changes to the Policy?

Portofino reserves the right to make changes to this Policy at any time. When we do, we will post the change(s) on our Site. While we do not intend to make changes to our Policy very often, it is always a good idea to check the Policy whenever you visit our Site to be sure that you have read and agree with our most current Policy. Our Policy’s effective date will always be set forth at the beginning of the Policy. Any changes will be immediately incorporated into this Policy and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so.

Any change to this Policy is effective immediately. Your continued use of the Site or any related Services after any changes are made to this Policy constitutes your acceptance of the changes. If any changes are unacceptable to you, you should cease all use of the Services.

If we make a change that will materially affect how we use and/or share personal information that Portofino already collected from you, we will provide appropriate notice to you and obtain your consent to the changes as necessary to comply with applicable law. If you do not consent to such changes, your personal information will continue to be used in a manner that is consistent with the version of this Policy under which it was collected, or the information will be deleted.

What types of personal information do we collect, and where and when do we collect it?

Personal information is generally defined as information that, by itself or in combination with other information, may be able to identify you or your household or could reasonably be associated with you or your accounts. Personal information that we may collect from you on or through the Services includes:

• Contact details such as your name, address, zip code, date of birth, telephone number, and email address if you subscribe to our newsletter or otherwise contact us;
• IP addresses or other online identifiers;
• Taste, dietary or product preferences, and details about any hobby or activity you like based on information you provide in communications you may send to Portofino
• Photographs (if you choose to upload a photo in your communications with us);
• Office address and other business information (if you are engaging with us in a business-to-business capacity);
• Communications and marketing preferences (such as your preference to receive from Portofino special deals and coupons, product information, healthy diet information, recipes, or cooking tips); and/or
• Demographic information (i.e., date of birth, gender, and geographical location at the city and zip code level only).

We will not ask you to provide us with sensitive personal information about yourself, such as your sexual orientation, citizenship status, religious beliefs, biometric or medical information, precise geolocation, or your race or ethnicity, and we ask that you do not provide such sensitive information to us when you interact with our Services. However, to the extent you choose to disclose any sensitive personal information to us (such as, for example, if you choose to provide us with medical information connected to a consumer complaint form), you hereby acknowledge and agree that such sensitive personal information may be processed by us in accordance with the terms of this Policy.

There are areas on the Site and certain Services where you may be asked to directly provide Portofino with personal information. There also are instances where personal information or other information may be collected from you in an automated manner when visiting our Site.

Personal information may be collected from you directly when you:

• request a free Portofino product sample;
• contact Portofino with questions or comments;
• request customer service and related assistance;
• use store locator services provided on or through the Site;
• participate in surveys, questionnaires, or contests; and/or
• sign up for any Portofino newsletters.

Portofino may automatically collect certain information specific to your computer or mobile device, such as your IP address, online identifiers, and your current location (for mobile devices), when you use such device(s) to visit or use the Site, but we will ask for your permission before collecting your precise location. For more information, please see the ‘What information is automatically collected through the Site, and why?’ section of the Policy, below. You can also turn off location data sharing on your mobile device at any time by modifying the sharing settings on your device. For the avoidance of doubt, we do not collect precise geolocation data (i.e., your exact GPS location).

Portofino may also indirectly infer your taste or product preferences, shopping preferences, and marketing preferences based on the personal information you provide to us in communications and/or through your interaction with our Services.

What do we do with personal information?

By providing Portofino with your personal information, you agree that we may use and share the information in accordance with this Policy. If you do not want us to use and/or share your personal information in accordance with this Policy, do not provide the information to us, visit our Site, or use our Services. We may use personal information you provide to us, depending on the circumstances and your reasons for providing us with the information, to:

• provide fulfillment services;
• respond to your questions or comments;
• process and catalog responses to surveys or questionnaires;
• enter you in contests or other promotions and notify you of results;
• send you emails and mail with updates and news related to promotions, contests, product information and new product introductions, new recipes and meal solutions, including healthy diet information and related informational content from our celebrity spokespersons;
• understand product usage and preferences as well as cooking habits;
• tell you what stores closest to you carry your favorite Portofino products;
• respond to your customer service requests and provide you with other assistance you request;
• understand and analyze in the aggregate demographic information about our customers;
• send out coupons, special deals, brochures, recipes, information and tips on cooking seafood, and other information on our products;
• deliver content on or through the Site, in addition to our other Services;
• improve the content and general administration of the Site;
• perform internal operations related to the Site (e.g., fraud prevention);
• troubleshoot software issues and operational problems with the Site;
• conduct data analysis and testing; and/or
• monitor usage of the Site.

As stated above, we do not knowingly collect your sensitive personal information and in the event that you voluntarily provide us with your sensitive personal information, we will not use it for profiling purposes or to infer characteristics about you. We do not use algorithms or other tools to make automated decisions about you.

In addition to the categories of personal information described above, we may also collect your signature and certain medical information when you submit to Portofino consumer complaint forms, medical release forms, dental release forms, other release forms or any cashed claim checks. In order to administer and process these forms that you sign, we may collect information on medical symptoms you claim to be experiencing. Portofino may share such information with our insurers as necessary to process your claim.

Where we ask you for your personal information due to statutory or contractual requirements, we will indicate which information is required and which is voluntary. However, if you do not provide us with certain information voluntarily, we may not be able to provide you with the respective products or services, or respond to your requests.

Portofino reserves the right to use, retain, or disclose any information as needed to satisfy any law, regulation, or legal request, to protect the integrity of the Site or our other Services, to fulfill your requests, or to cooperate in any legal investigation.

What information is automatically collected through the Site, and why?

Cookies to maintain our Site and to offer you a personalized experience

Portofino may use cookies and track IP addresses or other device information through the Site.

Cookies are small text files stored on a user’s hard drive which contain certain data about the user. IP addresses are the codes assigned to your computer or device as connected to the Internet. We use “cookie” technology and IP addresses only to obtain data about how visitors use our Site to provide them with the best possible personalized online experience. To do this we keep track of the type of browser (e.g., Microsoft Edge, Google Chrome) and operating system (e.g., Windows, macOS) used by visitors to the Site, and the domain name of the visitor’s Internet service provider. We also track the total number of visitors to our Site in an aggregate form so we can update and improve our Site. We also use cookies to help us figure out which of our web pages visitors stop at and how long they stay there. This helps us keep our Site fresh and interesting to our visitors. Cookie technology also helps us deliver content tailored to a visitor’s interests based on your browsing history when you interact with the different pages on our Site. You may disable cookies or set your browser to alert you when cookies are being used. However, if you disable cookies, it may affect how the Site appears and/or operates for you. For information on how to disable cookies please see our ‘Cookies’ section below, under the heading “How can you exercise certain rights and choices for personal information you supplied to Portofino?”

Third-party tracking technologies used on our Site

GOOGLE ANALYTICS TRACKING

This Site uses Google Analytics and Google Tag Manager, which are web analytics services provided by Google Inc. (“Google”). These services from Google use analytical tracking technologies to analyze your use of the Site. The information collected by these tracking technologies about your use of the Site is transmitted to and stored on a Google server in the United States. Information that Google may collect for analytical tracking purposes may include but is not limited to page views, scrolls, videos or links that were clicked, a unique client ID attributable to your device and browser information, your approximate age, gender, interests, language settings on your device or browser, and approximate location metadata derived from your IP address (city, state, and country). Google uses this information to assess your use of the Site and provide us with reports on data such as how often you visit the Site, what pages you view when you visit, and what other websites you have visited prior to visiting our Site so that we may have a better understanding of the web traffic on our Site and to personalize your experience. Google may transfer this information to third parties, if required by law or if third parties process the information on behalf of Google.

A general overview of Google’s data privacy practices for Google Analytics may be available at https://support.google.com/analytics/answer/6004245. For more information on Google’s privacy practices generally, please review Google’s privacy policy, which may be available at https://policies.google.com/privacy. To opt out of being tracked by Google Analytics, you may be able to download and install the Google Analytics Opt-out Browser Add-on, currently available at https://tools.google.com/dlpage/gaoptout. You can also limit data collection and sharing by configuring your Google Tag Consent settings, or by making selections through Google’s Ad Center.

THIRD-PARTY MARKETING PIXELS, COOKIES, AND OTHER TRACKING

This Site may use pixel tags, cookies, and related third-party tracking technologies and services that are operated by social media and ecommerce platforms, among other third-party services, including Facebook, Instagram, YouTube, and Amazon.

A pixel tag is a small graphical image, embedded on a webpage or in an email. When you access a page or email with a pixel tag, the tag generates a generic notice of that action. Pixel tags usually work in conjunction with cookies, by registering when a particular device visits a specific page or opens an email.

These third-party services may collect device-related data such as your IP address. Such tracking technologies are used to recognize your device when you return to the Site, learn about what ads you see and interact with, and to serve you with ads about products or services in which you may be interested based on your browsing activity before and after you leave the Site. Data collected through these practices also is analyzed to measure the effectiveness of ads for statistical and marketing research purposes. More directly identifiable information such as your name, email address, and other contact information generally is not processed through these third-party technologies.

You may have certain choices regarding the extent to which these third-party platforms and services collect and use your personal information. Details on how you may be able to exercise such choices are further detailed in the chart, below.

On the Site, you may use product locator services from third-party providers such as Destini to help you find places where Portofino products are for sale. Such third-party services use cookies that collect and store your browsing data for a period of time to determine whether you make a purchase after using the product locator. The amount of time these cookies are stored will depend on the applicable retailer, but the average is 30 days. Portofino uses these third-party services to keep track of when you use our Site to find places where you can buy our products.

Other online service providers and social media platforms (including the entities in the table above) may integrate with our Site through the use of online plugins and may allow you to share content from the Site with these third-party online services. Your use of such features may also enable the sharing of information with your friends or the public, depending on the settings you establish with the relevant social media service. Please note that Portofino has no control over how these online service providers and social media platforms collect, use, or share your personal information, and you should review the privacy policies of those online service providers and social media platforms to ensure you are comfortable with their privacy practices before you share personal information with them.

With whom do we share your personal information?

Third party service providers who collect/receive personal information

Portofino may use various service providers to perform activities for us or on our behalf in connection with the Site or our related Services, such as the vendors described in the table below, or other vendors that provide similar services. Such Portofino service providers are obligated to use and protect your personal information in accordance with this Policy.

Other Third Parties

In certain cases, we may share your personal information with other third parties including:

• our family of companies to contact you about relevant products or services;
• our business partners and/or marketing affiliates to assist with a particular Portofino promotional activity or to help us improve our products to better serve your needs;
• governmental authorities and law enforcement (if required under applicable law or pursuant to an investigation or to avoid imminent physical harm to any person or damage to any Portofino property);
• our insurers as necessary to carry out any complaint or claims process you may have initiated with Portofino and
• third parties involved in a potential or actual merger, acquisition, consolidation, bankruptcy, or any similar transaction or proceeding related to our ownership status, provided that the acquiring party shall be bound by obligations of confidentiality and data security with respect to disclosed personal information in a manner consistent with this Policy.

You acknowledge that such a merger, acquisition or other transfer may occur, and that any acquiring party of Portofino or its assets may continue to use your personal information as set forth in this Policy.

Other than what is identified above, your personal information will not be shared with or sold to any person or entity outside of Portofino. Please be aware, however, that you may choose to reveal personal information in public areas of the Site if you contribute any user generated content to our Site or our pages on social media platforms.

BY VISITING OUR SITE AND/OR PROVIDING TO PORTOFINO THE PERSONAL INFORMATION AND OTHER DATA REFERENCED ABOVE, YOU AGREE THAT PORTOFINO MAY USE THE PERSONAL INFORMATION AND OTHER DATA IN ACCORDANCE WITH THE TERMS OF THIS POLICY.

What about links to other sites?

We may offer links to external third-party sites, including those embedded in third-party advertisements or sponsor information, that are not owned or controlled by Portofino. For example, coupons for Portofino and other fine products may be made available through a link to an agent that specializes in the distribution of online coupons. We may also include links in emails to our sponsors’ sites with special offers, promotions, and information for our customers. Nevertheless, Portofino is not responsible for the content, privacy practices, and data collection policies of such third-party sites. If you visit any third-party site, you should review its privacy policy for details on how it handles your personal information. You visit such external third-party sites at your own risk.

How can you exercise certain rights and choices for personal information you supplied to Portofino?

In connection with our collection and use of your personal information, and depending on where you reside, you may submit requests to exercise rights or choices you may have in certain circumstances, such as rights or choices to:

• obtain access to or correction of the personal information in our custody or control;
• withdraw your consent to the collection, use, sale, or disclosure of your personal information, subject to contractual and legal restrictions;
• review details on the specific pieces of personal information that Portofino has collected about you;
• have Portofino delete or dispose of copies of personal information it has collected about you;
• opt-out of the sharing of your personal information for targeted advertising purposes;
• limit any processing of your sensitive personal information for purposes of inferring characteristics about you (Portofino does not engage in this activity);
• opt-out of any profiling or automated decision-making activities that may be made with respect to your personal information (Portofino does not engage in these activities); and/or
• not be discriminated against, in terms of the prices offered on or through our Services, because you exercised these rights regarding the collection, use, and sharing of your personal information.

How to Exercise your Rights or Choices.

If you would like to exercise any of the above rights or choices, please contact us at customerservice@portofinotuna.com. Portofino will not discriminate against you for exercising your rights under applicable privacy laws.

Verifying your Request.

Portofino is required to verify the identity of any person or entity that requests the disclosure or deletion of personal information. If you have a password-protected account with us, we may use our existing authentication procedures to verify your identity. For most other requests, Portofino will ask you to provide information that matches at least two pieces of personal information we store about you before responding to your request. If you would like to request the specific pieces of your personal information that we have collected, or if you would like us to delete highly sensitive personal information, you will need to match at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the consumer whose personal information you are requesting.

Please note that we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We may refuse any request made regarding collected personal information if we are unable to verify the identity of the person making the request or if we cannot authenticate the legitimacy of the request using commercially reasonable efforts. Under such circumstances, we may follow up with you for additional information as reasonably necessary to authenticate your request.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Authorized Agents.

You may grant an authorized agent written permission to submit requests regarding your personal information, but we may deny authorized agent requests if we are unable to verify your identity directly as the subject of the personal information at issue. In order to verify a request from an authorized agent, we may require proof that you gave the authorized agent signed permission to submit the request. This could include requiring you to verify your identity directly with us or directly confirming with us that you provided permission for the authorized agent to submit your request.

Responding to your Request.

After verifying your identity, we will respond to your request by either fulfilling your request or explaining why we are denying your request. The timeframe in which we respond will vary based on the applicable law where you reside. If we deny your request, you may have the option under applicable law to appeal this decision by contacting us using the methods described above. If you are concerned with the result of your appeal, you may have the right to contact your State Attorney General or applicable data protection supervisory authority.

Deletion Requests.

Please note that for deletion requests, any removal of content by Portofino does not ensure or guarantee complete or comprehensive removal in all places. The content may have been shared or reposted by other parties who act outside of any business relationship with us or who may not cooperate with our request for them to delete your personal information, or federal or state law may require maintenance of the content or information. Portofino will do its best to accommodate your request, but we cannot guarantee we can remove all personal information from the specified uses. Therefore, please be as specific as possible in your request. If the request relates to information that Portofino needs to make certain Services function properly for you, you may not be able to use those Services properly moving forward. Portofino reserves the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain your personal information.

Opt-Out of Certain Personal Information Use and Sharing Activities

THIRD PARTY SHARING

You may be able to opt-out of Portofino sharing your personal information with the third-party entities identified in this Policy by sending us an email at the address above, unless the sharing of your personal information is necessary to perform one of the following business purposes: auditing related to counting ad impressions and evaluating their effectiveness; to detect, protect against, and prosecute security incidents; to debug or troubleshoot functional errors that may arise with the Site or other Services; to complete short-term tasks related to an existing interaction you have with Portofino to maintain or service your account; to fulfill orders or requests for free samples; verify your customer information; or to ensure the safety and quality of the Site.

As referenced above, to opt out of being tracked by Google Analytics, you may be able to download and install the Google Analytics Opt-out Browser Add-on, currently available at https://tools.google.com/dlpage/gaoptout. You can also limit data collection and sharing in connection with Google Analytics by configuring your Google Tag Consent settings, or by making selections through Google’s Ad Center.

MARKETING EMAILS

We ask visitors to our Site and other users of our Services who provide Portofino with email addresses to let us know if they would like further information, special offers or updates from our Site or about our Services. We also offer users of our Services an unsubscribe or “opt-out” option at any time they wish to cease receiving promotional emails or other information from us. If you would like to opt-out of receiving promotional emails from Portofino please follow the opt-out instructions at the bottom of the email or send Portofino a detailed email at customerservice@portofinotuna.com.

TARGETED ADS

You can opt-out of receiving targeted ads served by us or on our behalf by emailing customerservice@portofinotuna.com or, depending on where you reside, by using our ‘Do Not Sell or Share My Personal Information’ form on our Site. If you opt-out, you will still see ads, but they will not be personalized based on your online activity. Please note that if you disable your cookies or upgrade your browser after opting out, you may need to opt-out again.

To learn about ways to opt-out of certain kinds of tracking for targeted advertising purposes, please visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser and device-specific, and there is no guarantee that these industry-provided opt-out tools will prevent all targeted advertising. You also have the option to configure your browser to send global privacy control signals to participating websites (which include the Portofino Site) for purposes of automatically opting out of targeted ad tracking. For instructions on how to opt out of targeted advertising via third-party pixels on our Site, please see the ‘THIRD-PARTY MARKETING PIXELS, COOKIES, AND OTHER TRACKING’ section, above.

Additionally, our Site may use cross-device tracking technologies to try and connect your activity on our Site across the various devices you use to access and use the Site. If you would like to opt-out of such cross-device tracking, please contact us at customerservice@portofinotuna.com.

COOKIES

With respect to opting out of the use of cookies on our website, most browsers allow you to block and delete cookies. You can change browser cookie settings to block/delete the cookies by going to the browser settings page (see, e.g., Chrome, Safari, and Firefox). If you are using any other web browser, please review your browser’s official support documents. With respect to cookie tracking, please note that some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked.

Information for California Residents

Pursuant to Section 1798.83 of the California Civil Code, also known as the “Shine the Light Law,” residents of California have the right to request certain information free of charge from a business with whom the resident has an established business relationship, with respect to the types of personal information the business shares with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights under the Shine the Light Law, California residents may make one request each year by emailing us at customerservice@portofinotuna.com.

California residents are also afforded additional protections under state law, including the right to know about our data processing activities over the last 12 months. California residents interested in learning more about such activities over the last 12 months may review our Annual Privacy Notice for California Residents, which supplements this Policy for such residents.

Does Portofino collect, use, or share information from children?

No. The Site is intended for, and Portofino only knowingly collects information, including personal information, from adults 18 years of age and older located in the United States. This Site is not directed at, marketed to, nor intended for, children under 18 years of age. Portofino does not knowingly collect any information, including personal information, from children under 18 years of age. If Portofino learns that any information was provided to it through the Site by a child younger than 18 years of age, Portofino will delete such information immediately.

Any minor, or the parent(s) or legal guardian(s) of such minor, who wishes to request the removal of the minor’s information should submit their request to customerservice@portofinotuna.com. Any removal of content by Portofino does not ensure or guarantee complete or comprehensive removal of the content in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information.

How do we safeguard your personal information?

Portofino implements, uses, and maintains industry standard technological security measures that are reasonably designed to help secure your non-public personal information from loss, unauthorized access, or disclosure, both in storage and in transmission.

While we have employed security technologies and procedures to help safeguard your personal information, no system or network can be guaranteed to be 100% secure, and you should exercise discretion in what information you disclose and/or transmit through the Site or our other online Services. Portofino cannot guarantee that information sent over the Internet is fully secure. The transmitted information may be intercepted by others before it reaches Portofino, for example. If you are concerned about sending information to Portofino over the Internet, please send the information by mail or call us to make other arrangements. Portofino is not responsible for the security of information sent over the Internet.

We also use reasonable efforts to be sure that third parties who work with us agree to protect personal information that they must access in order to serve our Site and our visitors.

For how long do we retain your personal information?

Portofino retains collected information for a reasonable amount of time in order to fulfill the stated purpose for why the information was collected. For example, information you submit that is connected to a consumer complaint will be retained for as long as necessary to carry out any related complaint or claims process that was initiated with Portofino. Additionally, we will periodically ask you if we can continue to retain your email address so that we can communicate with you for the purposes set forth in this Policy. Portofino will also retain collected information connected to business records for periods of time required by law. If Portofino determines that collected information is no longer needed, it will properly delete or dispose of any copies of such information. Our collection times will be consistent with applicable law.

Are there any other rules about how I can use the Site?

Your use of the Site is governed by the Terms of Use and Services for the Site, which is incorporated by reference into this Policy.

Who should I contact if I have a question or concern?

If you believe Portofino or another third party has violated this Policy, if you believe that personal information you supplied to Portofino has been compromised or inappropriately accessed by a person outside of Portofino, or if you have any questions about this Policy, please contact us at customerservice@portofinotuna.com. You may also call us at 1-888-244-9272 or write to us at:

Privacy Coordinator
Portofino
1875 Explorer Street, 10th Floor
Reston, Virginia 20190