PRIVACY
Effective as of June 30, 2021
Whole Earth Brands, Inc. and our employees, agents, subsidiaries, and affiliates (collectively, “Whole Earth Brands,” “we,” “our,” or “us”) are committed to safeguarding your personal information. We have adopted and implemented this privacy policy (“Privacy Policy”) as part of our commitment to protecting your personal information across all of our websites, mobile apps, and other online properties that link to this Privacy Policy (the “Sites”). This Privacy Policy applies only to the Sites, and covers only information collected in connection with your access to and use of the Sites. We encourage you to read this Privacy Policy to learn about how we collect, use, disclose, and protect your personal information and about the choices you can make regarding information you share. Whole Earth Brands is the entity responsible for processing personal information (i.e., the data controller) under this Privacy Policy.
Because we are a global company, this Privacy Policy takes into consideration various privacy regulations and frameworks governing the collection, use, maintenance, sharing, and disposition of personal information. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. In addition, while this Privacy Policy is intended to describe the broadest range of our personal information processing activities globally, the processing activities in some jurisdictions may be more limited based on restrictions under local laws or based on the products and services being offered.
Additional information relating to our practices and the rights of residents in specific countries is provided at the end of the Privacy Policy in the Country-Specific Notices section.
Consent to Privacy Policy
By using the Sites, you are agreeing to the practices described in this Privacy Policy and you expressly consent to provide all personal information to Whole Earth Brands through the Sites, including by email, blog post, or social media, as well as to processing by automated or non-automated means, for the purposes indicated in this Privacy Policy and subject to the Terms of Use that apply to the Sites.
Personal Information
Throughout this Privacy Policy, we use the term “personal information” to describe information that can be associated with an identified or identifiable person. “Personal information” may include, but is not limited to, your name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, date of birth, driver’s license number, or national ID number.
Changes to this Privacy Policy
We ask that you read this Privacy Policy from time to time. We may modify this Privacy Policy at any time in our sole discretion. If we make material changes to this Privacy Policy that increase our rights to use personal information we have previously collected about you, we will obtain your consent, where required by law, either through your registered email address or by prominent posting on this page.
The following topics are covered below (click on one of the links below to jump to the listed section):
1. Information We May Collect About You
2. Information We May Collect Through Automated Means
3. How We Protect Children’s Privacy
4. How We May Use the Information We Collect about You
5. Do Not Track
6. When We May Share Your Information
7. What We May Do With Your Social Network Account Information
8. How We May Use Cookies
9. How We Retain and Protect Your Information
10. Third-Party Advertisements
11. Business Transfers and Corporate Changes
12. Location and Transfer of Personal Information
13. Links to Other Websites and Third-Party Plug-ins
14. Additional State- and Country-Specific Notices
Notice to Residents of the United Kingdom, European Union, and Other Non-U.S. Countries
15. How You Can Contact Us
Information We May Collect About You
We may collect information about you when you interact with the Sites, including when you log in to the Sites, create an account, join our mailing list, make a purchase, request a service, request information, communicate with customer service, apply for a job, or upload content to the Sites through various means, including your social media account, which may feed information to the Sites. The information that we may collect includes, but is not limited to, the following:
Contact information (including name, postal addresses, email address, and telephone number);
Purchase and transaction information (including payment card information, billing and mailing addresses, and information about the products and services that you purchased);
Login credentials;
Demographic information (including age/birthdate, gender, and country in which you are located);
Information that you provide to us through the Sites regarding your eye color, skin, health, activities, and skincare concerns;
Social media handles;
Preferences regarding products and services;
Information that you choose to submit in connection with your comments or inquiries;
Photographs and other content that you provide;
Contact information for others (including email address) when you use certain features, such as “Send This Job to a Friend”;
Occupation, professional license number, license type, license expiration date, specialty skills, and company name (obtained from beauty professionals); and
Employment history, education history, and other information contained in a resume uploaded through our Site or submitted through an online application form (obtained from job applicants, to the extent permitted by applicable law).
Information We May Collect Through Automated Means
We may automatically collect information about the devices that you use to interact with the Sites, as well as information about how you interact with the Sites. The information that we automatically collect may include, but is not limited to, the following:
Precise geolocation (with your knowledge and consent);
Location (based on internet protocol (IP) address);
IP address and other device identifiers;
Browser type and version;
Operating system type;
Language your system uses and country and time zone where your device is located;
Information you searched for on the Sites;
When and for how long you visited the Sites;
Pages you visited while on the Sites;
Time spent on those pages; and
Web page that referred you to our Sites.
The information that we collect may be associated with any personal information that you have provided to us.
Your Precise Geolocation. When you interact with the Sites, you may be asked for permission to allow us to collect your precise geolocation information. If you consent to such collection, we may use this information to provide you location-based or targeted advertisements and social media posts; to locate our nearby retail or distribution partners; or for analytics purposes. You may discontinue our collection and use of geolocation information by changing the settings on your browser or mobile device.
How We Protect Children’s Privacy
Our Sites are general audience Sites not directed at children under the age of 13. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 13, we will promptly delete that information.
How We May Use the Information We Collect about You
We may use the information we collect about you to do the following:
Provide Products, Services, and Other Information, including Advertising, That May Interest You
Facilitate your transactions, including processing and fulfilling purchases, shipping orders, and personalizing the customer experience, where possible;
Send you promotional materials and other communications, in accordance with applicable laws;
Respond to your inquiries;
Send you email alerts relating to investor relations, if you request to receive them;
Communicate with you about, and administer your participation in, special events, contests, sweepstakes, programs, offers, loyalty programs, surveys and market research;
Deliver advertisements based on your interests;
Provide you with an interactive social media experience that allows you to connect your social networking community to the Sites;
Create and manage your account;
Process your employment application, and notify you of future employment opportunities that may be of interest to you; and
Help you locate distributors of our our products.
Manage and Improve our Business Operations
Operate and manage the Sites;
Operate, evaluate, and improve our business, including by managing, enhancing, improving, and analyzing our products, and the performance and functioning of the Sites; developing new products and services; managing our communications; and performing accounting, auditing, and other internal functions;
Enforce our agreements;
Study how consumers use the Sites; and
Perform other market research, such as determining trends and business opportunities based on consumer activity.
Ensure a Secure Online Environment and Comply with Legal Requirements
Protect against and detect fraud, abuse, and other unlawful activity;
Enforce the Sites’ Terms of Use, other corporate policies, and industry standards; and
Comply with all applicable laws and our reporting obligations.
Profiling. We may use your personal information to develop a personal profile about you to allow us, for example, to treat you in a more personal way as part of our customer outreach.
Opt-Out Policy. If you no longer want to receive marketing emails from us, please follow the “unsubscribe” instructions in the email you receive from us. We will process your request within a reasonable period of time. We are not responsible for removing your personal information from lists of any third party, such as a business partner, that has previously been provided with your information under this Privacy Policy. Where required by law, Whole Earth Brands will take reasonable steps to inform the applicable third parties of your request.
Analytics. We may use third-party analytics services, such as Google Analytics, on our Sites. The analytics providers may use technologies such as cookies, web server logs, and web beacons to help us analyze visitors’ use of our Sites. The information collected through these technologies, including your IP address, may be disclosed to the analytics providers and other relevant third parties that use the information to analyze the use of the Sites.
Do Not Track
We do not track customers over time and across third party websites to provide targeted advertising and therefore we do not respond to Do Not Track signals.
When We May Share Your Information
We may share your information with our affiliates and subsidiaries for the purposes described in this Privacy Policy, and with third-party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing or providing our products and services, sending you advertisements for our products, administering surveys or contests, hosting product reviews, or otherwise communicating with you.
In addition, as noted above, we may share your information with third-party analytics companies for the purpose of conducting research about how our Sites are used and what products and services consumers prefer. These third parties use this information to provide us the services and perform the functions for which we have contracted.
We also may provide to third parties, including other businesses and members of the public, aggregated statistical data showing general usage patterns and statistics, interactions, and transactions with our Sites. This data does not personally identify you or provide specific information about individual usage.
We also may share your information with third parties, including law enforcement authorities, where we determine that doing so is appropriate to:
Enforce our Terms of Use;
Protect our property, services, and legal rights;
Prevent physical harm to persons or to the property of others, financial loss, security incidents, or in connection with an investigation of suspected or actual illegal activity;
Prevent fraud against Whole Earth Brands and others;
Support auditing, compliance, and corporate governance functions;
Comply with subpoenas, court orders, or similar legal processes issued by law enforcement agencies, regulators, and courts; and
Comply with any and all applicable laws.
What We May Do With Your Social Network Account Information
Our Sites may allow you to sign in to your social network accounts, including, but not limited to, Facebook, Twitter, Instagram, and Pinterest, and associate them with our Sites. By using this functionality, you give us permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings on your social network account for information about what information is shared with us and other connected applications and to manage the information that is shared through your account, including information about your activities while using the Sites.
If you would like to disconnect a social network account from the Sites, refer to the settings of your social network account and its provider.
How We May Use Cookies
When you visit our Sites, we may place pieces of code, commonly referred to as “cookies,” or use similar technology (such as web beacons or browser-based local storage) on your devices. Where permitted by law, we may begin collecting information as soon as you visit the Sites. By using the Sites, you permit us to collect and use your information in accordance with this Privacy Policy. We may use cookies to customize your visits to the Sites, track usage patterns on the Sites, or analyze activity online.
Your internet browser or mobile device may allow you to block the transmission of certain information. For example, you may be able to configure your browser to notify you when you receive certain types of cookies, restrict or disable certain cookies, or block cookies altogether. You also may be able to delete certain cookies, called Flash cookies, by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on the Sites.
How We Retain and Protect Your Information
We have implemented an information security program that includes administrative, technical, and physical controls that are designed to reasonably safeguard information that can individually identify you.
You can unsubscribe to email, text, or other messages through your account settings or by following the instructions contained in the message. You also may ask us to update your information by contacting us at [email protected]. Unless you direct us otherwise, we reserve the right to retain your personal information to the maximum extent permitted by applicable law.
Third-Party
Third parties, including, but not limited to, advertisers, website hosting providers and digital marketers, may collect information about your activities over time and across different websites when you use the Sites. These third parties also may provide us with data collection, reporting, ad response measurement, analytical information, and assist with the delivery of relevant marketing messages and advertisements. These third parties may view, edit, or set their own cookies. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this Privacy Policy. Many third-parties, and some web browsers and mobile devices, allow you to opt out of third-party data collection.
Our Sites may use Google Analytics for advertising to collect analytics about how you use our Sites. We may use the Google Analytics cookie and Google advertising cookies together in order to collect data for advertising purposes. You can opt out of Google Analytics using Google’s Ad Settings, or by using the Google Analytics Opt-Out Browser Add-on. You also may opt out of tracking and receiving targeted advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.
Business Transfers and Corporate Changes
We reserve the right to disclose and transfer all information related to the Sites, including personal information:
To a subsequent owner, co-owner, or operator of one or more of the Sites; or
In connection with a corporate merger, consolidation, or restructuring; the sale of substantially all of our stock and assets; or other corporate change, including, without limitation, during the course of any due diligence process.
Location and Transfer of Personal Information
Whole Earth Brands is a global company and may collect and process information in countries throughout the world. Therefore, subject to applicable laws, your personal information may be located and processed in a country where Whole Earth Brands does business, other than your country of residence or the country from which you provided Whole Earth Brands with your personal information. These other countries may not have the same data protection laws as the country in which you reside.
In addition, we may transfer the personal information we collect about you through the Sites to our affiliates, subsidiaries, and service providers in other countries, such as to the United States, for the purposes described above. When we transfer your personal information to another country, we do so in accordance with applicable law.
When we transfer personal information from the European Economic Area (EEA), the United Kingdom (UK) or Switzerland to non-EEA and UK countries, we rely on approved data transfer mechanisms, such as Standard Contract Clauses, which may be requested by contacting us at [email protected]. By providing us with your information through the Sites, you consent to this collection, processing, and transfer of your personal information.