EFFECTIVE FEBRUARY 2019

Privacy Policy

LAST UPDATED: MARCH 4 2021

True Citrus Company (“True Citrus”, “us“, “we“, or “our“) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process in connection with our goods and services found at www.truelemon.com and other web domains by which we provide products and services online (collectively, the “Site”). This Privacy Policy (the “Policy”) describes our privacy practices and those of our vendors and business partners on the Website (“Service Providers”), but we do not own, operate, or control, the privacy practices of such Service Providers.

We collect and use information from or about you according to the Privacy Policy in effect at the time the information is gathered. Please be aware that our Privacy Policy may be changed by updating this page. You should review this Privacy Policy periodically to ensure you are in agreement with any updates or changes. Your continued use of our website following any changes will mean you accept such changes.

This Policy covers all personal information collected through this Site, through the provision of services to you, as described in our Terms and Conditions, which can be found at https://www.truelemon.com/pages/terms-conditions and is incorporated herein by reference. We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services available on the Website.

Please read this Privacy Policy carefully to understand how we treat your personal information and what choices and rights you have in this regard. If you do not agree with the terms and conditions of this Policy, you should not access or use the Website or our services. By downloading, using, accessing, visiting, or registering with the Site, by submitting your information through the Site, or by engaging in any online communications with us concerning our products or services, you consent to this Policy and to our collection and sharing of your information in accordance with the terms of this Policy.

About Us

The Website provides information and an online retail store for our citrus flavoring, seasoning and beverage products, recipes for True Citrus products, newsletters, contest offers, and blogs on the topic of active healthy lifestyles, and special promotions for products, and other services (collectively “Services”).

What Personal Information Do We Collect and Why?

We may collect or request anonymous or non-personally identifiable information from visitors. Non-PII cannot identify a specific individual unless combined with Personally Identifiable Information. An example of Non-PII is aggregate information which we use for a variety of reasons, including to calculate the percentage of our Website visitor’s users that live in a particular state or the pages visited most frequently.

We may collect and processing the following personally identifiable information (which may constitute “PII” or “personal data” under certain data protection laws) from you for the following purposes:

Category	Types of Data & PurposSensitive Personal Information
Contact Information	When you visit our Site or ask for services, we may ask you for your name, address, telephone number, email address or other contact details in order to respond to your requests or inquiries.
User Account Information	When you create an account, we collect your contact information, other identity information (e.g., age, gender, date of birth, photo), other demographic information (location), username and password, and other registration information, including payment information. This information is necessary to enable us to provide you the account you have requested and to maintain the account and your profile. You may update your account information by editing the information associated with your account.
Conference Registration Information	When you register for a conference or seminar hosted by us, we collect your contact information and other details necessary for processing the registration, including payment information.
Business Information	When you seek services from us in the course of contractual or customer relationships between you, your organization and us, we collect business contact information and other personal information in order to provide you with the services you have requested.
Financial and Payment information	When you purchase goods or services from with us, we may collect your bank account and other data necessary to process payments, including credit card numbers, security codes, expiration dates, and other related billing information.
Location Information	When you use our Site, we may collect information about your use of our Site and services for advertising, analytics, to serve content and to protect our Site and services. Location information collected may include your Internet Protocol (IP) address, or other similar location-tracking technologies.
Cookies	When you visit our Site, we may collect cookies and use similar technologies to, among other things, provide you with a more personal and interactive experience on our Site, to improve our marketing efforts, and for usage analytics for our Site (e.g., page response times, download errors, length of visit, webpages visited, etc.). Please see our Cookies and Similar Technologies Policy: https://www.truelemon.com/pages/cookie-policy/ for more information. If you choose to disable cookies and similar technologies, some areas and features of the Website may not work properly.
Automated Information	When you visit our Site, we automatically collect information from your browser or your mobile device, such as Internet Protocol (IP) address or unique device identifier, cookies and data about which pages you visit in order to allow to operate and provide the Website and our services. This information is used to protect our Site and services and to keep the Website secure, to analyze and improve our Site and services and understand how the Website works for users, and to provide advertising to you and a more personalized experience for our users. To learn more about our collection of technical data, please visit: https://www.truelemon.com/pages/terms-conditions
Email Interconnectivity	If you receive email communications from us, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. We use this information to enhance our marketing efforts.
Employment	If you apply for a job, or become an employee, we collect personal information necessary to process your application or employment. This may include, among other things, your contact information, your social security number, employment history, etc.
Feedback/Support Inquiries	If you provide us with feedback or contact us for support or ask us questions, we will collect your name, email address, other contact information and other information needed to respond to your feedback, request for support, or answer your question.
Mailing List	When you sign up for one of our mailing lists, we collect your contact information, including your email address and postal address.
Social Media	When you submit a survey, questionnaire, contest entry, or comment form by using the Website or social media or other online survey tools and platforms accessible via our Website, we or third parties who operate those tools, platforms, or social media websites may collect your social media handle or profile, or any other identifier that you use by which you may be contacted online or offline.
Order Placement	When you place an order with or purchase goods or services from us, we collect your name, billing address, shipping address, phone number, email address, and contact details, shipping preferences, and payment information.
Text Marketing and Notifications	By entering your phone number in the checkout and initializing a purchase, subscribing via our subscription form or a keyword, you agree that we may send you text notifications (for your order, including abandoned cart reminders) and text marketing offers. Text marketing messages will not exceed 10 per month. You acknowledge that consent is not a condition for any purchase. If you wish to unsubscribe from receiving text marketing messages and notifications reply with STOP to any mobile message sent from us or use the unsubscribe link we provided you with in any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests will not be accounted as a reasonable means of opting out. Message and data rates may apply. For any questions please text HELP to the number you received the messages from. You can also contact us for more information. If you wish to opt out please follow the procedures above.
Sensitive Personal Information	When necessary in order to respond to your requests for services or employment, we may collect information regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, financial information, or data concerning your sex life or sexual orientation. We will collect this sensitive personal information with your express consent or as otherwise permitted by applicable law.
Your Communications	When you communicate with us, we may retain your communications in order to process and respond to them, as well as improve our services. We may use your email address to communicate with you about our products and services or send you periodic emails if you decide to opt-in to any of our mailing lists. If at any time you would like to unsubscribe from receiving future emails, you may unsubscribe using the link at the bottom of each email. Text

How Will We Use Your Personal Information?

In addition to the uses described above, True Citrus uses the personal information collected in an effort to improve your experience on the Site, to provide services to you, and to communicate with you about the information you have requested. We may also use personal information to help target specific offers to you and to help us develop and improve our Site and services.

Additionally, we may use your personal information in the following ways:

To provide you with services you have requested and to manage our relationship with you, including administering your account, processing payments, accounting, auditing, billing and collection and taking other steps necessary to the performance of our business relationship with you;
To present and improve Website contact and functionality;
To determine user interests, needs and preferences;
To provide notice of changes to our Website or the services we offer or provide through it;
To conduct research and analysis;
To develop new products and services;
To manage and maintain the security of our Website and services;
To market our services to you. We will only provide you with marketing related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time. True Citrus does not sell, rent or lease it's customer lists to third parties.
To comply with our legal and compliance obligations, including maintaining records, performing compliance audits, etc.
For insurance purposes;
To exercise and defend our legal rights, or to comply with court orders;
To respond to requests from public and government authorities;
For any other purpose related to and/or ancillary to any of the purposes and use described in this Policy for which your personal information was provided to us;
In any other way we may describe when you provide the information; and
For any other purpose to which you have consented.

We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
Because we have a necessary and legitimate interest in doing so to perform the services you have requested, to comply with your instructions or other contractual obligations between you and us;
To comply with our legal obligations as well as to keep records of our compliance processes;
Because our legitimate interests, or those of a third party recipient of your personal information, makes the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
Because you have chosen to publish or display your personal information on a public area of the Website, such as blog or comment area;
Because it is necessary to protect your vital interests;
Because it is necessary in the public interest; or because you have expressly given us your consent to process your personal information in a particular manner.

We do not use your personal information for making any automated decisions affecting o recreating profiles other than as described above.

Disclosure of Your Personal Information

We may share your personal information in the following contexts:

Category	Disclosure Contexts
Contact Information	When you visit our Site or request our services, we may ask you for your name, address, telephone number, email address, or other contact details in order to respond to your requests or inquiries about our Site or services.
Business Information	When you seek services from us in the course of a contractual or customer relationship, we collect business contact information and other personal information in order to provide you with the services you have requested. This includes your name, company email, website URL, phone number, job title, and other information about your company.
Public Areas	Some areas of our Site provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit your personal information in these areas, you do so at your own risk and acknowledge that the information will be publically-available.
Job Applications and Employment	When you apply for a job with us, we collect personal information necessary to process your application or employment. This may include, among other things, your contact information, your social security number, employment history, etc.
Email Interconnectivity	If you receive email communications from us, we may use certain tools to capture data related to when you open our message, click on any links, or banners it contains. We use this information to enhance our marketing efforts.
Directories	There may be times when we will seek your express consent through an online account or conference/seminar registration to having your contact information shared with other account holders or conference/seminar registrants.
Feedback / Support / Inquiries	If you provide us with feedback, contact us for support, or ask us questions via web form, telephone, email, or other method allowed by our Website, we will collect your name, email address, other contact information and other information needed to respond to your feedback, request for support, or answer your question.
Third Parties	We may provide personal information about you to third parties that offer products and services when expressly requested by you.
Mailing List and Newsletters	When you sign up for one of our mailing lists or newsletters, we collect your contact information, including your name, company name, email address, postal address, and telephone, as necessary to complete your sign up.
Service Providers	We may share your personal information with our Service Providers. Among other things, Service Providers may help us to administer the Website, support our provision of services requested by you, provide technical support, send marketing, promotions and communications to you about our service, payment processing and other legitimate purposes permitted by law.
Sensitive Personal Information	When necessary in order to respond to your requests for services or employment, we may collect information regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, financial information, or data concerning your sex life or sexual orientation. Industrial Strength Marketing will only collect this sensitive personal information with your express consent or as otherwise permitted by applicable law.

Payment Information

We use Shopify / Shopify-Plus (collectively, “Shopify”) as the e-commerce shopping cart solution on our Website.

Credit and debit card information, as well as other personal information, collected by our third party payment processor, Shopify, are governed by Shopify’s Privacy Policy at https://www.shopify.com/legal/privacy, and any other relevant policies posted on the Shopify website.

Shopify is certified as a PCI DSS Level 1 compliant service provider, and follows industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other personal information entrusted to Shopify.

How Long Do We Store Your Personal Information?

We will retain your personal information for as long as needed to fulfill the purposes for which it was collected. We also will retain and use your personal information as long as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, provide our services, and enforce our agreements.

When we no longer have a purpose to retain your personal information, we will security destroy your personal information in accordance with applicable law and our policies. We take reasonable steps to delete the personal information we collect if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. To the extent permitted by law, we may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.

Security Of Your Personal Information

We maintain appropriate technical and organizational measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized manner, altered or disclosed during collection, storage, and processing. While our security measures seek to protect your personal information in our possession, no security system is perfect and we cannot guarantee that your personal information will remain absolutely secure in all circumstances or that any privacy settings or security measures contained on the Website cannot be circumvented.

The majority of communications on our Site, including any submissions through available forms, are sent through the standard HTTP protocol and may be delivered using regular e-mail. Information sent over HTTP is not encrypted. E-mail, while convenient, does pose some risks (e.g., e-mail is not a secure form of communication, is unreliable, can be forwarded, etc.). The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Website, you are responsible for keeping the password confidential. Do not share your password with anyone.

If a security breach causes an unauthorized intrusion into our Site or systems that compromises your data, we will notify you and any applicable regulator when we are required to do so by applicable law.

Updating Your Personal Information

If you of the personal information you have provided to us changes, please let us know. For instance, if your email changes, you wish to cancel any request you have made of us, or if you become aware of inaccurate personal information about you, use our Contact Us details to update your information. You may also edit your account details if you have a user account through our site.

We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Your Rights To Access And Control Your Personal Information

Please use the Contact Us details at the end of this Policy to exercise your rights and choices under this Policy.

Right of Access. If required by law (e.g., under the GDPR), upon request, we will grant reasonable access to the personal information that we hold about you.

Accuracy. Our goal is to keep your personal information accurate, current and complete. Please contact us if you believe your information is not accurate or changes.

Right to Object. In certain circumstances, as permitted under applicable law, you have the right to object to processing of your personal information and to ask us to erase or restrict our use of your personal information. If you would like us to stop using your personal information, please contact us and we will let you know if are able to agree to your request.

Right to Erasure and Deletion of Your Personal Information. You may have a legal right (for instance, if you are located in the EU or EEA under the GDPR) to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your personal information has been unlawfully processed. All deletion requests should be sent to the address noted in the Contact Us section of this Policy.

We may decide to delete your personal information if we believe it is incomplete, inaccurate or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete personal information, it will be removed from our active servers and databases and our Site, but it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Withdraw Consent. If you have provided your consent to the collection, processing and transfer of your personal information, you have the right to fully or partially withdraw your consent. To withdraw your consent, please notify us using the information in the Contact Us section of this Policy and you may follow opt-out links on any marketing communications sent to you.

Once we have received notice that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.

Right to Complain. If you believe that your rights relating to your personal information have been violated, you have a right to lodge a complaint with the applicable enforcement or supervisory authority, or seek a remedy through the courts. You may also lodge a complaint with us by contacting us using the information provided in the Contact Us section of this Policy.

Online Tracking

We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions.

California Residents. California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing. If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Contact Us” section of this Policy.

European Union or European Economic Area Residents. If you are located in the EU or EEA and believe we have not processed your personal information in accordance with applicable provisions of the EU GDPR, you may lodge a complaint with your local data protection or supervisory authority.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the CCPA Privacy Policy for California residents here: https://www.truelemon.com/pages/privacy-policy-california

Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of the Site may make any changes to their information at any time by contacting us at customercare@truecitrus.com.

Cross-Border Transfers of Personal Information

We are located and established in the United States and therefore, your personal information may be transferred to, stored or processed in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the security and privacy of your personal information.

By using our Website or requesting services from us, you understand and consent to the collection, storage, processing and transfer of your personal information to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy. Residents of the EU / EEA. We rely on recognized legal bases to lawfully conduct cross-border transfers of personal information outside of the European Union (EU) and European Economic Area (EEA), such as your express informed consent (as noted above), when transfer is necessary for us to deliver services pursuant to an agreement or contract for services between us and you, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses.

Children’s Online Privacy Protection Act

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and services are not directed to children aged 13 or younger, nor is information knowingly collected from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or provide any information to or on the Site. If you are under 13 years of age, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, and username). If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 13 without his/her parent’s consent, please contact us using the contact information provided below.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

Links To Other Sites

This Policy is applicable only to True Citrus and the specific processing activities defined in this Policy. It does not apply to any third-party websites.

This Site may contain links to, and media and other content from, third party websites. These links are to external websites and third parties with which we have no relationship. If you click on an embedded third-party link, you will be redirected away from this Website to the external third-party website. You can check the URL to confirm that you have left this Website.

We cannot and do not (i) guarantee the adequacy of privacy, security, practice content or media provided by third parties or their websites, (ii) control third parties’ independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Site.

Any personal information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

International Visitors

The Site is controlled and operated from the United States. If any materials on the Site are contrary to the laws of the place where you are when you access them, then we ask you not to use the Site. You are responsible for informing yourself of the laws of your jurisdiction and complying with them. By using the Site, you consent to the transfer of information to the United States, which may have different data protection rules than those of your country.

Governing Law

This Privacy Policy and any disputes related thereto shall be governed by and construed in accordance with the laws of the State of Maryland, exclusive of its choice of law rules.

Updates And Changes To This Policy

We reserve the right, at any time and without notice, to add to, change, update, or modify this Policy to reflect any changes to the way in which we treat your personal information or in response to changes in law. Should this Policy change, we will post all changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will also notify you through a notice on the home page of the Site for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting on the Site. The date on which this policy was last modified is identified at the beginning of this Policy.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, engaging with us on social media, or communicating with us, from time to time, so that you are aware of any changes. Your continued use of the Site, engaging with us on social media, or communicating with us in any format after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your personal information according to the terms of the then-current Policy.

How To Contact Us

If you have questions or concerns regarding our Website, Privacy Policy, or practices, please contact us at:

Email: customercare@truecitrus.com

U.S. postal address:

Attn: True Citrus Consumer Affairs

True Citrus Company

11501 Pocomoke Court

Suite D

Baltimore, Maryland 21220

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