Clif Bar Privacy, Cookies Notice for the EEA
SCOPE OF THIS NOTICE
Clif Bar & Company ("Clif Bar," "we", "us", "our") provides to residents of the European Economic Area (EEA) this Privacy, Cookies Notice (“Privacy Statement”).
CONTROLLER AND EU REPRESENTATIVE
Clif Bar & Company 1451 66th Street, Emeryville, CA, 94605, USA, operates this site and www.clifbar.com (collectively, the “sites”) and is the controller of any personal data collected or otherwise processed on or through the sites. Our authorized representative in the EU is Clif Bar Europe B.V., Prince Bernhardplein 200, 1097 JB Amsterdam, the Netherlands.
INFORMATION WE COLLECT. In accordance with this Privacy Statement, Clif Bar collects information from you directly and indirectly as you use our sites. Such information includes personal data.
Information You Provide to Clif Bar. Users of our sites provide the following types of personal data in order to register, access various content or features, submit content, directly contact us with questions or feedback, or access other features of our sites:
• Contact information, such as name, address, telephone number, or e-mail address
• Country of residence information
• Communications preferences
• Personal interests and profile information
• Search queries
• Comments and other information posted through interactive online features
• Correspondence you send to us
• Information collected offline, such as if you contact Customer Service other than via the Services
Information We Automatically Collect. When you use our sites, some information is automatically collected. For example, when you visit our sites your computer's operating system, Internet Protocol (IP) address, access times, browser type and language, and the website you visited before our websites may be logged automatically. We also collect information about your usage and activity on our sites like pages you visit and links you click.
PURPOSES AND LEGAL BASES FOR PROCESSING
We process your personal data on several different legal bases, as follows:
1. Based on necessity to enter into or perform a contract with you - we need to process your personal data to enter into an agreement with you or a legal entity you represent, to perform contractual obligations, to respond to related questions and requests from you, or provide customer support.
2. Based on legitimate interests - we process personal data from you
• for the security and safety of the sites, our IT connected to the sites and the users of the sites;
• to protect and defend the rights or property of others, or our own rights and interests;
• to track your activities on the sites and present you advertising based on your browsing activities and interests, provided you have not opted out of such data processing. Detailed information about the web analytics and advertising solutions used on the sites can be found immediately below.
|Name and Provider of Solution||Purpose of Solution|
|Google Analytics by Google, Inc., USA||Evaluating your use of the sites, compiling reports on website activity for us and providing other services relating to website activity and Internet usage to us.|
|Optimizely||Stores a visitor’s unique Optimizely identifier, a combination of a timestamp and random number to conduct A/B testing. No other information about you is stored inside.|
|New Relic||Evaluating your use of the sites, compiling reports on website activity for us and providing other services relating to website activity and Internet usage to us.|
|Double Click||Ad targeting based on what’s relevant to a user, to improve reporting on campaign performance and to avoid showing ads the user has already seen.|
3. Based on compliance with legal obligations - we may need to process your personal data to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal process;
Cookies Used On the sites
The cookies we use can be categorized as follows:
|Strictly Necessary Cookies||
These are cookies that are required for the operation of the sites or of certain parts thereof. They either serve the sole purpose of carrying out network transmissions or are strictly necessary in order for us to provide an online service explicitly requested by you.
These cookies allow us to carry out web analytics or other forms of audience measuring such as recognizing and counting the number of visitors and seeing how visitors move around the sites. This helps us to improve the way the sites works, for example, by ensuring that users are easily finding what they are looking for.
These cookies are used to recognize you when you return to the sites. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). Loss of the information in these cookies may make our services less functional but would not prevent the sites from working.
These cookies record your visit to the sites and/or your use of the services, the pages you have visited and the links you have followed. We will use this information to make the sites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
|Demographic Information Cookies||
These cookies collect and retain limited demographic information such as date of birth and gender, if such information is provided by the user, which is tied to anonymous identifiers and may be referenced by the system for some tailored advertising.
The following cookies are used on the sites:
|Cookie Name||Cookie Solution Provider||Cookie Category|
However, please be aware that this might render certain functions of our sites inoperable or more difficult to use. Depending on the Internet browser you use, you might also be able to specifically reject third-party cookies. In this context, please note, however, that third parties might still have access to your Personal Information to the extent that such information is logged by first-party cookies.
For additional information on first-party and third-party cookies used on our sites in the context of third-party services and for information on how you might stop such cookies from being stored on your device, please see “Third-Party Services” below.
Marketing Communications to You
On www.clifbar.com, you can register to receive newsletters or similar information on our products or services or the products or services of our affiliated companies. As part of the registration process, we ask you to provide us with certain mandatory information. Such information includes your first and last name, postal code, gender, how you heard of us, product you are discussing and product flavor and your comments.
When receiving a registration, we may log and store the date/time of registration and the IP address the registration was received from. This solely serves evidentiary purposes should your contact details be used by an unauthorized party.
When registering to receive newsletters or similar information on clifbar.com or our local sites for each of the EEA countries, you need to explicitly declare your consent to our processing of your personal data for this purpose. You are under no obligation to provide such consent and, if you choose to do so nonetheless, you may withdraw your consent at any time with future effect for any or no reason by following the unsubscribe link contained in any email communication to you or by sending us an email at email@example.com.
RECIPIENTS OF YOUR PERSONAL DATA
In the following circumstances, we disclose your personal data to the following third parties, as required or permitted by applicable law:
|Who Is your Personal Data Disclosed To?||What Is the Purpose Underlying the Disclosure?|
|Companies affiliated with Clif Bar & Co. Inc. including: Clif Bar Europe B.V.||To enter into an agreement with you or a legal entity you represent, to perform contractual obligations, to respond to related questions and requests from you, or provide customer support. For example, we may use data about how you use our products to enhance your user experience and to help us diagnose problems and to administer our sites and applications;|
|Third-party suppliers and service providers including:||To assist us in the operation or improvement of the sites and to enhance our products and services;|
|To other third parties in line with applicable legal requirements (where applicable)||To comply with legal obligations that we are subject to;|
DATA TRANSFERS TO RECIPIENTS OUTSIDE OF THE EU/EEA
We are headquartered in California, USA, a jurisdiction outside the European Union and for which the European Union Commission has not issued an unlimited adequacy decision. When you use our sites, you send personal data to the United States. To operate our sites and our business, we also share personal data with affiliated and unaffiliated service providers outside the European Economic Area (EEA). To ensure an adequate level of protection of your personal data with respect to affiliated and unaffiliated service providers outside the EEA, we enter into data processing and data transfer agreements that incorporate the Standard Contractual Clauses approved by the EU Commission. You can ask for a copy of such appropriate safeguards by contacting firstname.lastname@example.org.
HOW LONG WE KEEP YOUR PERSONAL DATA
Personal data processed in the context of a contract with you will be retained by us for the term of the contract and for a reasonable time afterwards as might be required to determine and settle any related claims. Where our processing of your personal data is based on legitimate interests or the compliance with legal obligations, it will be deleted as soon as the underlying purpose has expired. Personal data processed based on your consent will be deleted if and when you withdraw such consent.
YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA
Subject to the conditions set out in the applicable law, you have, without limitation, the rights to (i) inquire whether and what kind of personal data we hold about you and how it is processed, and to access or request copies of such personal data, (ii) request the correction or supplementation of personal data about you that is inaccurate, incomplete or out-of-date in light of the purposes underlying the processing, or to (iii) obtain the erasure of personal data no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, processed for legitimate interests that, in the context of your objection, do not prove to be compelling, or processed in non‑compliance with applicable legal requirements. In addition, you have, subject to the conditions set out in the applicable law and without limitation, the rights to (iv) request us to restrict the processing of personal data in certain situations where you feel its processing is inappropriate, (v) object, in certain circumstances, to the processing of personal data for legitimate interests, and to (vi) request portability of personal data that you have actively or passively provided to us (which does not include data derived or inferred from the collected data), where the processing of such personal Data is based on consent or a contract with you and is carried out by automated means. In case of concerns, you also have the right to lodge a complaint with the competent local data protection authority.
You may exercise the above mentioned rights of access, rectification, erasure, restriction, objection and data portability by contacting us under email@example.com, even to the extent that such claims relate to the processing of personal data by one or more of the data recipients identified in this Privacy Statement.
EFFECTIVE DATE AND CHANGES
This Privacy Statement is effective June 1, 2018. We may make changes, including material changes, to this Privacy Statement from time to time. You should review the Privacy Statement each time you visit this site to learn of any changes.
If you have questions about this Privacy Statement, please contact us at firstname.lastname@example.org.