PORTOFINOTUNA.COM PRIVACY POLICY/YOUR PRIVACY RIGHTS

Privacy Policy/Your Privacy Rights

Effective as of: April 20, 2022

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

Portofino cares about your privacy when you visit and interact with the Site. We want to tell you in detail about the policies and practices which we have adopted to protect your privacy so that you can feel confident about how we handle the personal information you choose to entrust to us online. We hope that you enjoy our Site and will come back often to visit! As such, Portofino’s privacy practices are explained in this Privacy Policy (“Policy”)

This Policy only covers the Site identified above, and does not apply to information you send to us by other means. Other sites owned or controlled by Portofino may have their own privacy policies and should be reviewed.

The Site is directed at U.S. citizens 18 years of age and older, located only within the United States. If you use the Site outside of the United States, you do so at your own risk and are responsible for complying with your local laws and regulations.

Portofino requires its employees involved with the collection of information to be familiar with this Policy.

IF YOU ARE UNDER 18, PLEASE BE SURE TO READ THIS POLICY WITH YOUR PARENTS AND ASK QUESTIONS ABOUT THINGS YOU DO NOT UNDERSTAND. Portofino only knowingly collects information, including personally identifiable information, from persons 18 years of age and older. The Site is not directed at, marketed to, nor intended for, children under 13 years of age. Portofino does not knowingly collect any information, including personally identifiable information, from children under 13 years of age. If Portofino learns that any information was provided to it through the Site by a child younger than 13 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 and end 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 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 Site.

If we make a change that will substantially affect how we use and/or share personally identifiable information that Portofino already collected from you, we will provide appropriate notice to you, and give you thirty (30) days to opt-in to the changes as they pertain to your information. If you do not opt-in, your 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 personally identifiable information do we collect and when do we collect it?

Personally identifiable information (“PII”) is generally defined as information that, by itself or in combination with other information, may be able to identify you or could reasonably be associated with you or your accounts. PII could include, but is not limited to, name, address, telephone number, email address, username and password, IP address or other online identifiers, credit/debit card number or other financial information, professional or employment-related information, office address and other business information, communications preferences, demographic information, etc.

There are areas on the Site where you may be asked to provide Portofino with PII, or where such PII or other information may be collected from you in an automated manner.

For example, PII (or other related data) including, but not limited to, names, mailing and/or shipping addresses, e-mail addresses, phone numbers, photographs, hobby or activity information, age, gender, taste or preference information, product preferences, shopping preferences, and marketing preferences (such as your preference to receive from Portofino special deals and coupons, product information, healthy diet information, recipes, and/or learning tips on how to cook seafood) may be collected from you when you:

  • register for a loyalty program;
  • 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; and/or
  • participate in surveys, questionnaires or contests

Portofino may collect certain information specific to your mobile device, such as your location, when you use such device(s) to visit or use the Site, but we will ask your permission before doing so.

What do we do with the personally identifiable information?

By providing Portofino with your PII, 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 PII in accordance with this Policy, do not provide the information to us.

We may use PII you provide to us, depending on the circumstances and your reasons for providing us with the information, to:

  • register you for a loyalty program or other features available on or through the Site;
  • 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;
  • 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 services on or through the Site;
  • 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.

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

Portofino may use cookies and track IP addresses 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 unique code assigned to your computer 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 do keep track of the type of browser (e.g., Internet Explorer, Chrome) and operating system (e.g., Windows, Macintosh) used by the visitor 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 to allow us to 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 the majority of our visitors. Cookie technology also helps us deliver content tailored to a visitor’s interests. You may disable cookies or set your browser to alert you when cookies are being sent. However, if you disable cookies, it may affect how the Site appears and/or operate for you.

How do we use cookies and other third party tracking technologies?

GOOGLE TRACKING

The Site uses Google Analytics and Google Tag Manager, which are web analytics services provided by Google Inc. (“Google”). These services from Google use cookies to analyze your use of the Site. The information collected by these cookies about your use of the Site (including your IP address) is transmitted to and stored on a Google server in the United States. Google uses this information to assess your use of the Site, providing reports on data such as how often you visit the Site, what pages you view when you visit the Site, and what other websites you have visited prior to visiting our Site. Google may transfer this information to third parties, if required by law or if third parties process the information on behalf of Google.

View an overview of Google’s data privacy practices for Google Analytics. For more information on Google’s privacy practices generally, please review Google’s privacy policy.

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.

FACEBOOK MARKETING PIXEL

The Sites also may use a pixel tag provided by Facebook, which could automatically collect certain data about how you use various aspects of the Sites in a manner similar to cookies. As a result, you may receive ads that are personalized from what you appear to be interested in based on your online behavior, both on the Sites and elsewhere. Visitors may be able to opt-out of certain targeted advertising that Facebook provides by following the instructions in Facebook’s Ad Settings. To learn more about how Facebook handles Personal Information and other data it may collect from you, please see Facebook’s Data Policy.

OTHER THIRD PARTY SERVICE PROVIDERS

Portofino may use hosting service providers, such as New Relic, to host and help secure the Site. These hosting services help us make sure you are able to access the Site, and to protect against any potential attacks on the Site or our servers. Accordingly, these services are essential to our ability to secure and provide the Site, along with any services related to the Site. For more information on how providers like New Relic handle any PII and other information collected from you for these purposes, please visit New Relic Privacy Policy.

Portofino may use service providers to assist consumers to find our products in stores and with online retailers, such as Destini, to help visitors to the Site identify products in which they are interested, and to help them locate where such products can be purchased in the stores near them or online. For more information on how Destini treat collected PII and other information, please visit Destini Privacy Policy

Portofino may also collect and share with its marketing vendors or service providers information related to: (1) what links and web pages visitors access on the Site; (2) how long visitors to the Site stay at certain pages; and (3) how visitors to the Site got to the specific pages (via advertising, email blasts, online banners, etc.).

All of the above-referenced cookies, IP addresses and marketing information will be collected and managed by our outside marketing vendors in order to provide you with targeted ads based on what you appear to be interested in as a result of your activity online, both on our Site and elsewhere. You can opt-out of receiving targeted ads served by us or on our behalf by visiting Portofino’s privacy policy. 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 will need to opt-out again. Further, if you use multiple browsers or devices you will need to execute this opt-out on each browser or device.

You can also generally opt-out of receiving targeted ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) by visiting Network Advertising Initiative opt out. You may opt-out of receiving targeted advertisements from other companies that perform interest-based advertising services, including some that we may work with, via the Digital Advertising Alliance (DAA). Please note that when using the ad industry opt-out tools described above, you may need to execute opt-outs for each browser or device that you use, and that other companies’ opt-outs may function differently than our opt-out.

The Site may use cross-device tracking technologies to try and connect your activity on the 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 customercare@starkist.com

Portofino may use third-party marketing service providers, such as Scanova, to provide you with links to our Sites or other Portofino content online when you scan a dynamic QR code in Portofino advertisements. QR codes are a type of barcode that can be used to provide you with information and content when you scan them using your mobile device. The marketing service provider Portofino uses to provide you with the link from the QR code to Portofino’s content online may need to collect your IP address in order to link you to our Sites or other content. To learn more about how Scanova handles your IP address and any other data it collects through this process, please visit Scanova Privacy Policy.

By providing to Portofino the PII and other information referenced above, you agree that Portofino may use the PII and other information in accordance with the terms of this Policy.

With whom do we share your personally identifiable information?

We use a third party information storage vendor to store and secure any PII we collect from you. The vendor will not share your PII in any manner inconsistent with this Policy.

Portofino uses a customer service provider to receive and respond to customer service requests from visitors to the Site. As part of this, Portofino may share your email address and related PII with its customer service provider in order for it to accomplish this task.

We may also share your PII with our business partners who are joining us in a particular promotion or activity and/or our marketing affiliates who assist us with compiling standard demographic and product usage information in order to help us with product improvement and development. The information is used solely by us, our agents (such as advertisers and marketers responsible for compiling and analyzing this information for Portofino) or business partners to respond to your requests and to better serve you.

Certain areas on the Site may integrate with social media sharing services which will let you share content from the Site with other online services. Your use of such features may enable the sharing of information with your friends or the public, depending on the settings you establish with the relevant social sharing service. Please review the privacy policies of those social media services for more information about how such services handle the information you provide to or share through them.

Portofino will disclose your PII or other information if it reasonably believes it is required to do so by law or in cooperation with a governmental or law enforcement investigation. Portofino may also share PII or other information in order to avoid imminent physical harm to any person or harm to any Portofino property.

Although your PII will not be sold, Portofino may disclose your PII to an actual or potential acquiring party of all or a substantial portion of Portofino or Portofino’s assets through a merger, asset purchase or consolidation, or even through bankruptcy or similar proceedings. Such acquiring party shall be bound by contractual obligations to protect the confidentiality and privacy of the PII disclosed to them and to secure such information in a manner consistent with this Policy. You acknowledge that such transfers may occur, and that any acquiring party of Portofino or its assets may continue to use your PII as set forth in this Policy.

Other than what is identified above, your PII 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 PII in public areas of the Site if you contribute any user generated content.

What about links to other sites?

We may offer links to other external third party sites, including those embedded in third party advertisements or sponsor information, that are not 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. It is our policy to try to link only with sites that share our views on privacy. Nevertheless, Portofino is not responsible for the content, privacy practices and data collection policies of such third party sites. If you visit another site, you should review its privacy policy for details on how it handles your PII. You visit such external third party sites at your own risk.

Portofino may also allow interaction between the Site and other online services such as social media providers. This may include plugins available through the Site that allow you to share information with persons outside of the Site. Please consult the privacy policies of such third party providers before using them to make sure you are comfortable with the level of sharing.

How can you review, edit or delete personally identifiable information you supplied to Portofino?

In connection with Portofino’s collection and use of your PII, you have the right:

  • to request access to or correction of the PII in Portofino’s custody or control;
  • to withdraw your consent to the collection, use, sale or disclosure of your PII, subject to contractual and legal restrictions;
  • to request details on the specific pieces of PII that Portofino has collected about you;
  • to request that Portofino delete or dispose of copies of PII it has collected about you; and
  • to not be discriminated against, in terms of the services and prices offered on or through our Site, because you exercised these rights regarding the collection, use and sharing of your PII.

If you would like to access, review, edit, delete or have us properly dispose of any copies of the PII that Portofino collected about you (subject to any applicable legal exceptions), would like to opt out of receiving further information or limit what we share, or if you would like to exercise the above rights in any other way, please contact us at customercare@starkist.com

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

Please note that Portofino will do its best to accommodate any request to delete or properly dispose of any copies of your PII, but we cannot guarantee we can eliminate all PII from the specified uses. Therefore, please be as specific as possible in any request to delete or dispose of copies of your PII. If you choose to delete certain portions of your PII, it may affect your ability to use certain services or elements of the Site. If the request relates to information that Portofino needs to make the Site function properly for you, you may no longer be able to use the Site.

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 PII.

Portofino does not knowingly collect any information from minors, and the Site is not directed at or intended for minors. If a minor’s information is uploaded or posted through the Site, such information becomes publicly available, and the minor wants that same information deleted, destroyed or otherwise properly disposed of, the minor has a right to request that such information be removed from public viewing. 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 customercare@starkist.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.

Portofino does not recognize or process “do not track” or similar technical requests sent as a result of choices you make in your computer or browser settings.

Does Portofino collect, use or share information from children?

No. The Site is intended for, and Portofino only knowingly collects information, including PII, from persons 18 years of age and older located in the United States.

The Site is not directed at, marketed to, nor intended for, children under 13 years of age. Portofino does not knowingly collect any information, including PII, from children under 13 years of age. If Portofino learns that any information was provided to it through the Site by a child younger than 13 years of age, Portofino will delete such information immediately.

How do we safeguard your personally identifiable information?

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

While Portofino takes the issue of protecting your PII seriously, you should exercise discretion in what information you disclose and/or transmit through the Site. Portofino cannot guarantee that information sent over the Internet is fully secure. The transmitted information may be intercepted by others before it reaches Portofino. 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 our best efforts to be sure that third parties who work with us agree to protect PII that they must access in order to serve our Site and our visitors.

Portofino retains collected information for a reasonable amount of time in order to fulfill the stated purpose for why the information was collected. 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 la

What if I am located outside the United States?

The Site is meant for individuals within the United States. Portofino only knowingly collects information from individuals within the United States. If you provide information to Portofino from outside of the United States, you do so at your own risk. If you are outside of the United States, you are responsible for complying with any local laws regarding your use of the Site, and any related data collection. You also agree and acknowledge that by providing any information, including PII, through the Site, that such information will be transmitted to, and stored in, the United States.

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. The Terms of Use and Services for the Site can be found at Portofino Terms of Use and Services

What else should I know?

Notwithstanding the foregoing, 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, to fulfill your requests, or to cooperate in any legal investigation.

It is the policy of Portofino to strictly enforce this Policy. If you believe Portofino has violated this Policy, if you believe that PII 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

customercare@starkist.com

You may also call us at 1-888-207-1466
.

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

This Policy was last updated on April 20, 2022.