BONITA PACKING CO.
Consumer Privacy Policy

Last Updated: June 2023

Your privacy is very important to us. In general, you can browse www.bonipak.com (the “Site”) without telling us who you are or revealing any personal information about yourself. This policy explains the rights of California residents regarding the collection, use, sale, and sharing of their personal information under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We may update and make changes to this policy, so we encourage you to review it periodically.

  1. Personal Information We May Collect About You. We collect personal information in a variety of contexts. For example, we collect personal information as part of business transactions, for our human resources, and for vendor management purposes. The personal information that we collect about a specific California resident will depend on, for example, our relationship or interaction with that individual.

    During the past 12 months, we have collected the following categories of personal information:

    1. Personal identifiers such as full name and federal or state issued identification numbers including Social Security number, driver’s license number, and passport number.
    2. Personal information, including contact details (e.g. name, address, email address, telephone number), employment information (e.g. education, employment, and employment history) financial/payment details (e.g. account numbers, credit and debit card numbers), and medical and health insurance information.
    3. Characteristics of protected classifications such as race, age, sex, disability, citizenship, and military or veteran status. The Company is required to collect certain information about employee and applicants’ protected classifications by law.
    4. Purchase information, including products and services obtained and transaction history.
    5. Biometric information, including facial imaging for employee time reporting.
    6. Internet or other online information such as browsing history, search history, and information regarding your interaction with internet web sites and applications.
    7. Geolocation data, including data available from Company-issued vehicles or electronic devices.
    8. Audio and visual information, including audio, electronic, visual, thermal, olfactory, or other similar information, such as call and video recording.
    9. Professional or Employment information such as work history, prior employer, references, qualifications, skills and experience, human resources data, emergency contact information, and data necessary for benefits and related administrative services.
    10. Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (“FERPA”).
    11. Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    12. Sensitive personal information, including:

      1. Social security, driver’s license, state identification card, or passport number, collected to confirm ability to work in the U.S. consistent with applicable law.
      2. Geolocation data, which may be collected from Company-issued vehicles or electronic devices.
      3. Health information.

  2. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, in paper (e.g. paper applications or employment forms), text or email, or our website. However, we may also collect information from the following categories of sources:

    • Publicly accessible sources;
    • Third party (e.g., sanctions screening providers, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers);
    • Third party with your consent;
    • Cookies on our website;
    • Automated information collection;
    • Our IT systems.

  3. Why We Use Your Personal Information. We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be exhaustive.

    • Auditing Interactions with Consumers. For example: monitoring traffic to our website and auditing legal and regulatory compliance.
    • Security. For example, maintaining the safety, security, and integrity of our IT systems, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests or court orders and to comply with any applicable laws and regulations.
    • Debugging/Repair. For example, identifying and repairing errors in our website’s functionality.
    • Performing Services. For example, creating, maintaining, customizing and securing customer accounts, processing purchases, transactions, and payments, managing databases, performing analyses, and billing.
    • Quality and Safety Maintenance and Verification. For example, improving, upgrading or enhancing our operations, and verifying the quality or safety of our operations.
    • Human Resources Functions. To fulfil Human Resources functions or obligations, including recruitment, employee complaint resolution, and benefits administration.
    • Legal Compliance. To fulfil our legal functions or obligations.
    • Other Commercial Purposes. Examples include: (i) purposes as described to you when collecting your personal information:  (ii) if you sign up for cookies or other tracking devices may be used to personalize your experience; (iii) and to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information we hold is among the assets transferred.

    If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

    In response to a verified consumer request to know what personal information was collected or sold, we will investigate and provide an individualized response to the consumer, which will include the business or commercial purpose for collecting and/or sharing that information. We will not merely refer the consumer to our general practices outlined in this Privacy Policy unless our response would be the same for all consumers and this Privacy Policy discloses all the information that is otherwise required for the response to such a consumer request.

  4. Selling/Sharing Personal Information. We DO NOT SELL OR SHARE your personally identifiable information. The Company has no knowledge of selling or sharing personal information of consumers under 16 years of age.
  5. Categories of Personal Information We Disclosed for a Business Purpose. The Company has not disclosed personal information to any third parties for a business purpose.
  6. Use or Disclosure of Sensitive Personal Information. The Company does not disclose sensitive personal information for purposes other than those specified in 11 C.C.R., § 7027(m).

  7. How Long Your Personal Information Will Be Kept. We will keep your personal information for as long as is necessary while you are employed by us. Thereafter, we will keep your personal information:

    • To respond to any questions, complaints or claims made by you or on your behalf;
    • To show that we treated you fairly; or
    • To keep records required by law.

    We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

  8. Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), and certain other privacy and data protection laws, as applicable, to exercise free of charge:


    Disclosure of Personal Information We Collect About You

    You have the right to know, and request disclosure of:

    • The categories of personal information we have collected about you, including sensitive personal information;
    • The categories of sources from which the personal information is collected;
    • Our business or commercial purpose for collecting, selling, or sharing personal information;
    • The categories of third parties to whom we disclose personal information, if any; and
    • The specific pieces of personal information we have collected about you.

    Please note that we are not required to:

    • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
    • Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
    • Provide the personal information to you more than twice in a 12-month period.
    Right to Limit Use of Sensitive Personal Information

    You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

    • Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
    • To perform the following services:
      • Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;
      • Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;
      • Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and
      • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and
    • As authorized by further regulations.

    The Company does not disclose sensitive personal information for purposes other than those specified in 11 C.C.R., § 7027(m).
    Right to Deletion

    Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

    • Delete your personal information from our records;
    • Direct any service providers or contractors to delete your personal information from their record; and
    • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

    Please note that we may not delete your personal information if it is reasonably necessary to:

    • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
    • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;
    • Debug to identify and repair errors that impair existing intended functionality;
    • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
    • Comply with the California Electronic Communications Privacy Act;
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
    • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
    • Comply with an existing legal obligation; or
    • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
    Right of Correction If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
    Protection Against Retaliation

    You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

    • Deny goods or services to you;
    • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
    • Provide a different level or quality of goods or services to you; or
    • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

    Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

  9. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you may call us at 1-805-922-7982 or write to us at 1850 W. Stowell, Santa Maria, CA 93458. Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

    If you choose to contact us directly in writing or by phone, you will need to provide us with:

    • Enough information to identify you (e.g., your full name, address and customer or matter reference number);
    • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
    • A description of what right you want to exercise and the information to which your request relates.

    We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

    Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.