PRIVACY POLICY

Effective Date: 9/27/2023

Last Updated: 9/27/2023

This website (“Website”) is provided by Trident Seafoods Corporation (“Trident”, “we”, “us”, or “our”). This Privacy Policy (“Privacy Policy”) applies to the website on which it is posted, and all subdomains, other websites, applications, widgets, products, services, and other offerings (collectively, the “services”) owned and operated by Trident (including its affiliates) that link to this Privacy Policy. The services include https://www.tridentseafoods.com/, https://purealaskaomega.com, and https://louiskemp.com. This Privacy Policy applies to the personal data that we collect when you access and use our services, or when you otherwise interact with us through the websites where we post this Privacy Policy. By using these services, or indicating your consent to this Privacy Policy through the banner displayed to first-time visitors who visit the Website, you signify your agreement to the terms of our privacy policy. If you do not agree with these terms, please do not disclose any personal information (or “personal data”) through this site. If you are a resident of California, you may be entitled to exercise additional consumer rights and request additional information regarding our privacy practices relating to your personal data. Please see the “Consumer Privacy Rights Under State Law” section for more information.

If you are a resident of the European Union, Switzerland, or the United Kingdom, you may be entitled to exercise additional rights as a data subject and request additional information regarding our privacy practices relating to your personal data. Please see the “Consumer Privacy Rights in the European Union, Switzerland, and the U.K.” section below for more information.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access our websites or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

Information that We Collect

We collect personal data through your use of our services, as explained in more detail below. The specific information that we collect from or about you depends on the context of your interactions with us and our services, the choices you make, and the products and features you use, as described below.

Automatically Collected Personal Data

When you interact with the services, our servers may automatically keep a log of certain information reflecting your use of our services, some of which may qualify as personal data. Generally, we collect and store the following categories of information about our visitors:

• Demographic data such as age, gender, and five-digit zip code

• Device information about your computer, browser, mobile device, or other device that you use to access the services.  This information may include IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information.

• Analytics and usage information about your use of the services. 

• Additional “traffic data” and log files such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses.

• Other information regarding your use of the services.

Use of Cookies and Other Tracking Technologies

Like many websites and mobile applications, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We may also use cookies to monitor traffic, improve the Website and make it easier and/or relevant for your use. 

We use both “session” cookies and “persistent” cookies.  We do not use flash cookies, web storage, web beacons, or other technology that tracks your browsing history across multiple websites.

We use cookies for the other purposes set out below: 

• We use “functionality” cookies to remind us who you are and to find your account information in our database when you access a service so you do not need to log in at every visit. This helps us to provide you with services tailored to your specific needs and interests. A cookie is created when you register for an account on our service  We also use “functionality” cookies to determine the browser the visitor uses so the site can be designed to work properly with the most common versions of different browsers. 

• We use “analytics” cookies in conjunction with analysis of your use of our website —specifically, to generate analytics regarding our services, and to estimate our audience size. Your browser is given a unique cookie that helps us determine whether yours is a repeat visit or a first visit. 

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your cookie preferences by visiting our cookie banner at any time. If you delete your cookies or if you set your web browser to decline cookies, some features of the services may not work or may not work as designed.  For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org. We do not sell or “share” personal information with any third parties for profit.

Use of Your Personal Data

We use the personal data that we collect about you for various business purposes as described below, in each case as permitted by applicable laws as described below, in each case as permitted by applicable laws:

1. To provide you with our services by:

   1. Entering into a contract with you

   2. Allowing you to review our products

   3. Fulfilling your requests for products and services (such as by shipping samples and orders to you, and e-mailing you regarding shipment confirmations or order cancellations)

   4. Communicating with you about your account and updates to our services

   5. Processing applications, transactions, and payments

2. For our legitimate interests, which include:

   1. Personalizing content on our Website, including providing you with marketing content, reports, recommendations, and feedback based on your preferences, subject to applicable laws

   2. Optimizing or improve our Website, products, services, and operations

   3. Verifying your identity and preventing fraud

   4. Detect, investigate, and prevent malicious, deceptive, fraudulent, or illegal activities, or other activities that may violate our policies or be illegal.

   5. Debugging to identify and repair errors

   6. Enforcing our Terms of Service and policies

   7. Audit or other compliance activities

   8. Performing statistical, demographic, and marketing analyses of users of the Website and their purchasing patterns.

3. To comply with our legal obligations

We store personal data for as long as you use our services or as may be necessary to fulfill the purposes for which the information was collected or for legitimate business purposes. For example, we retain information where we are required by law, or if we are compelled to do so by a court order or regulatory body. Also, when you exercise any applicable legal rights you have to access, amend or delete your personal data, we may request identification and verification documents from you for the purpose of confirming your identity. In exceptional cases, we may further process your personal data to protect your vital interests or as further required for the public good.

Additionally, note that we use personal data to create de-identified, aggregated information such as: information about demographics, de-identified location information, information about devices used to access our services, and de-identified, aggregate information regarding use of our Website and related services to provide us with a better understanding of our users. Statistical, anonymized, and aggregated information that we derive from personal data is excluded from the definition of personal data because it does not personally identify you.

For more information about the cookies that we deploy, please click on our cookie banner at the bottom of the webpage.

Sharing of Personal Data

We do not rent nor sell your personal data. We may share or disclose your personal data in an identifiable form as provided below.

Service Providers: We engage service providers to perform tasks on our behalf, and we need to share your information with them in order to provide products or services to you. For example, we may use a payment processing company to receive and process any credit card transactions for us. We may also use a software vendor to assist us in measuring the effectiveness of our advertising.

Business Transfers: We may share your personal data with our affiliates and subsidiaries for the purposes described in this Privacy Policy. We may also choose to buy or sell our company assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal data could be one of the assets transferred to or acquired by a third party.

Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of our company, our employees, our users, or others.

Privacy Rights and Options

Opt-Outs

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us, use our services or to take advantage of some of our features.

Opting Out of Communications: If you no longer wish to receive electronic communications from us, click the unsubscribe link at the bottom of the email or follow opt-out instructions provided in other communication channels. Note you may still receive transactional emails from us. We process requests to be placed on do-not-mail and do-not-call lists as required by applicable law.

Opting Out of Cookies: You may stop or restrict the placement of cookies on your device or remove them as your browser or device permits, and by visiting our cookie preferences banner.

Updating Your Account Information: Through your account settings, you may access, and, in some cases, edit or delete the following information you have provided to us:

• name

• email address

• location

• payment information

The information you can view, update, and delete may change as the services change. If you have any questions about viewing or updating information we have on file about you, please contact us as described below.

Certain jurisdictions (including the European Union, the United Kingdom, and California) may provide you with additional consumer privacy rights. For more information, please see “Consumer Privacy Rights Under State Laws” and “Consumer Privacy Rights in the European Union, Switzerland, and the U.K.” below.

Do-Not-Track

We recognize and honor the following opt-out preference signals: “Do Not Track” and Global Privacy Control. To learn more about how to implement opt-out preference signals and/or Global Privacy Control, you should consult your browser’s privacy settings or visit the Global Privacy Control website.

Note that our acknowledgment of opt-out preference signals is based on browser settings, not your device. If you use multiple devices, or if your browser settings do not carry over between devices, you may need to implement such opt-out preference signals across each of your devices and browsers to ensure that your preferences are properly recognized.

Security

We take commercially reasonable and appropriate measures to help us in protecting the personal data that we collect from unauthorized access, use, disclosure, alteration, or destruction. Unfortunately, no data transmission or storage system is guaranteed to be 100% secure. As such, we are unable to guarantee the security of your personal data. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

You are advised to prevent unauthorized access to your personal data and other account details by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. You should use caution whenever submitting information online and take special care in deciding which information you provide.

Consumer Privacy Rights Under State Laws

If you are located in the United States, you may have additional privacy rights under the law of the state in which you reside.

Privacy Rights in California

This section describes the rights provided to “consumers” under the California Consumer Privacy Act (“CCPA”), and explains how to contact us in order to exercise those rights. For purposes of the CCPA, personal data that we collect is used and processed by the following third parties as indicated below:

Under the CCPA, consumers have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal data we collected about you.

• The categories of sources for the personal data we collected about you.

• Our business or commercial purpose for collecting that personal data.

• The categories of third parties with whom we share that personal data.

• The specific pieces of personal data we collected about you (also called a data portability request).

• If we sold or disclosed your personal data for a business purpose, two separate lists disclosing:

  • sales, identifying the personal data categories that each category of recipient purchased; and

  • disclosures for a business purpose, identifying the personal data categories that each category of recipient obtained.

Consumers have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies. You also have a right not to receive discriminatory treatment from us that is based on the exercise of your privacy rights.

We do not collect or use personal data for targeted advertising at this time, nor do we ‘sell’ or ‘share’ your personal data as defined by the CCPA. Additionally, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our services that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes.

Exercising Rights

To exercise your rights under State Privacy Law, you may submit your request by e-mail at privacy@tridentseafoods.com or by calling our toll-free number at (866) 413-4749.

[GW1]@Trident: If you would like to use a toll-free number dedicated to privacy requests, please replace this number.

Please note that we may request further information regarding your identity at the time of your request. We cannot respond or provide you with personal data if we cannot verify your identity and authority to make the request and confirm that the personal data relates to you.

You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will only use personal data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

The rights above may be limited in some circumstances, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to your request.

If you wish to designate an authorized agent to make a privacy request for you, please email us from the email address associated with your account and inform us of this designation, along with the designated agent’s name and email address.

Consumer Privacy Rights in the European Union, Switzerland, and the U.K.

If you use the Website, are located in Europe, and are subject to any one of (i) the General Data Protection Regulation, (ii) data protection laws implemented by member states of the EU in harmony with the General Data Protection Regulation, or (iii) the U.K. Data Protection Act of 2018, as amended and incorporated into U.K. law (collectively, the “GDPR”), the following applies with respect to your rights to exercise control over your personal data. Under the GDPR, you are a “Data Subject” and we are a “Data Controller” for any personal data that constitutes “personal data” under the GDPR that is processed under this Privacy Policy.

If you are not a Data Subject, the provisions in this section do not apply to you.

Lawful Grounds for Processing personal data of Data Subjects

We rely upon the following legal grounds to process personal data under the GDPR:

• If you have consented to the processing of personal data for one or more specific purposes.

• If the processing is necessary for the performance of an agreement with you (including for any pre-contractual obligations thereof), for our compliance with a legal obligation to which we are subject, to protect your vital interests or of another natural person, or otherwise for our legitimate interests.

• If the processing relates to a task that is carried out in the public interest or in the exercise of official authority, as permitted by law.

Data Transfer Notice

We use servers located in the United States to process your personal data. By using our services, you acknowledge and agree that we are authorized to transfer your personal data for processing in the United States. Under the GDPR, the transfer of personal data to a country outside the EU may take place where the European Commission has determined that the country ensures an adequate level of protection. The transfer of your personal data to the United States in the absence of an adequacy decision by the European Commission is made because it is necessary for the performance of a contract with you, or with your explicit consent.

Retention of personal data

Pursuant to the GDPR, we will permanently erase your personal data at such time there is no lawful basis or legal obligation for us to store or process the personal data.

Individual Rights and Data Subject Requests

If you are a Data Subject and we process your personal data, you may exercise certain rights under the GDPR, which are described below. We will endeavor to respond to any requests within 30 days from receipt, but in some instances it may take longer. We will inform you within 30 days from receipt of your request if an extension is necessary and the reason for the delay.

To exercise your lawful rights as a Data Subject (enumerated below), please contact us as specified in Section 9, and provide specific and detailed information about your request necessary for us to respond to and carry out your request.

• You may object to processing: You may object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).

• You may request to be informed about our processing: You may request information about how we process your personal data and request additional information about how to exercise your rights under the GDPR.

• You may obtain access to your personal data: You may obtain access to your personal data that we process.

• You may request rectification: If you believe any personal data that we process is incorrect or incomplete, you may request that we correct it.

• You may request deletion of your personal data: Under certain conditions, you may request that we remove or delete your personal data. For example, if there is no legitimate reason for us to continue processing it. In accordance with applicable law, we may retain certain personal data to keep a record of our compliance with your request.

• You may restrict our processing of your personal data: You may request that we cease further processing of your personal data. If you make such a request, we may continue to store your personal data but will not make further use of it.

• You may withdraw consent: If we are relying on consent as the lawful grounds on which we process your personal data, you may withdraw your consent for such processing at any time without affecting the lawfulness of processing based upon your consent before it is withdrawn.

In addition to the rights granted by applicable laws, you may submit a complaint about our processing of your personal data to your national data protection regulator.

Contact Us

If you have any questions or concerns regarding our privacy policies, you may contact us at legalnotice@tridentseafoods.com