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PRIVACY




PRIVACY POLICY

Effective as of 12/08/2020

Our commitment to transparency applies not only to the food we source, but also
to the data we collect about you, how it is used and with whom it is shared.
This Privacy Policy describes how Grocery Delivery E-Services USA, INC. dba
HelloFresh (“HelloFresh”, “we”, “us” or “our”) collect, use and share your
personal information in connection with your use of our websites (collectively,
the “Site”), mobile applications (collectively, the “App”), and social media
pages that link to this Privacy Policy (together with the “Site” and “App”, the
“Service”); and in the context of certain offline activities described in this
notice.


WE PROVIDE IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS HERE.

TABLE OF CONTENTS
PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR PERSONAL INFORMATION
HOW WE SHARE YOUR PERSONAL INFORMATION
YOUR CHOICES
OTHER SITES AND SERVICES
SECURITY PRACTICES
INTERNATIONAL DATA TRANSFERS
CHILDREN
IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS




PERSONAL INFORMATION WE COLLECT

INFORMATION YOU PROVIDE TO US.

Personal information you may provide to us through the Service or otherwise
includes:

- Contact data, such as your first and last name, email and mailing addresses,
postal code, and phone number.
- Profile data, such as your username and password that you set to establish an
online account with us, and other information you include in your account
profile.
- Communications that we exchange when you communicate with us, such as when you
request support, contact us with questions or feedback or complete our surveys.
- Content, such comments, text, images, audio, video or other content you post
to or provide through the Service.
- Payment and transactional data, such as the information needed to complete
your orders on or through the Service (including name, credit card information,
billing and shipping information), information about your payment transactions,
and your order history.
- Marketing data, such as your preferences for receiving communications about
our products, activities, events, and publications; details about how you engage
with our communications; and information you provide when you participate in an
event, contest or promotion.
- Other information that we may collect which is not specifically listed here,
which we will use as described in this Privacy Policy or as otherwise disclosed
at the time of collection.

Other sources. We may combine personal information we receive from you with
personal information we obtain from other sources, such as:
- Data providers, such as information services and data licensors.
- Public sources, such as public social media platforms.
- Business partners, such as joint marketing partners and event co-sponsors.

Automatic collection. We, our service providers, and our business partners may
automatically log information about you, your computer or mobile device, and
your activity over time on the Sites and other online services, including:
- Device data, such as your computer or mobile device opersuch as your computer
or mobile device operating system type and version number, manufacturer and
model, browser type, screen resolution, IP address, the website you visited
before browsing to our website, and general location information such as city,
state or geographic area.
- Online activity data, , such as pages or screens you viewed, how long you
spent on a page or screen, navigation paths between pages or screens,
information about your activity on a page or screen, access times, and duration
of access. Precise geolocation data, such as when you authorize our mobile
application to access your location.
- Security data, such security camera footage recorded at our offices or
facilities.

Cookies and similar technologies. Some of our automatic data collection on the
Site is facilitated by:
- Cookies, which are text files that websites store a visitor‘s device to
uniquely identify the visitor’s browser or to store information or settings in
the browser for the purpose of tracking user activity and patterns, helping you
navigate between pages efficiently, remembering your preferences and generally
improving your browsing experience.
- Flash cookies, or locally-stored objects, which are used for purposes similar
to cookies but allow storage of a larger amount of data.
- Web beacons, also known as pixel tags or clear GIFs, typically used to
demonstrate that a webpage or email was accessed or opened, or that certain
content was viewed or clicked, typically to compile statistics about usage of
websites and the success of marketing campaigns.
- Software development kits,or SDKs, which are used to incorporate third party
computer code into our App that allows the third party service providers or
advertising partners to collect data directly from it for a variety of purposes,
including to provide us with analytics regarding the use of the App, to
integrate with social media, add features or functionality to our app, or to
facilitate online advertising.

Information about others. You share personal information about others with us,
such as when you send them a gift through the Service or refer friends or other
contacts to us. When you share the personal information of others with us, you
are responsible for ensuring you have their permission to do so.

Information we obtain from social media platforms. Information you provide when
you interact with us on social media. If you choose to log in to the Service
through a social network or other third party platform, or otherwise connect
your account on a third party platform to your account through the Service, we
may collect information about you from that platform or network. For example,
this information may include your username, user ID, profile picture, cover
photo, email address and other contact information, and your affiliations. You
may also have the opportunity to provide us with additional information through
the third party platform, such as a list of your friends or connections. Read
more about third party platforms in the Your Choices section below.


HOW WE USE YOUR PERSONAL INFORMATION

Service delivery. We may use your personal information to:

- provide, operate and improve the Service and our business;
- facilitate your authentication to the Service by logging into a third party
platform, such as Facebook or Google;
- enable security features of the Service, such as by sending you security codes
via email or SMS, and remembering devices from which you have previously logged
in;
- facilitate social features of the Service, such as by identifying and
suggesting connections with other users of the Service and providing chat or
messaging functionality;
- communicate with you about the Service, including by sending you
announcements, updates, security alerts, and support and administrative
messages;
- understand your needs and interests, and personalize your experience with the
Service and our communications;
- provide support and maintenance for the Service; and
- to respond to your requests, questions and feedback

Research and development. We may use your personal information for research and
development purposes, including to analyze and improve the Service and our
business. As part of these activities, we may create aggregated, de-identified
or other anonymous data from personal information we collect. We make personal
information into anonymous data by removing information that makes the data
personally identifiable to you. We may use this anonymous data and share it with
third parties for our lawful business purposes, including to analyze and improve
the Service and promote our business.

Marketing and advertising. We and our third party advertising partners may
collect and use your personal information for marketing and advertising
purposes:

Direct marketing. We may send you HelloFresh-related or other direct marketing
communications as permitted by law, including text messages that you may opt to
receive from us that may include information about promotional offers and more.
These messages may use information automatically collected based on your actions
while on our Site or App and may prompt messaging such as cart reminders. If you
opt to have SMS notifications sent to your mobile phone, we receive and store
the information you provide, including your telephone number or when you read a
text message. You may opt-out of our marketing communications as described in
the Opt-out of marketing section below For more information about text messages,
see our Terms and Conditions.

Interest-based advertising. We may contract with third-party advertising
companies and social media companies to display ads on our Service and other
sites. These companies may use cookies and similar technologies to try to tailor
the ads you see online to your interests based on your activity over time across
our Service and other sites, or your interaction with our emails. These ads are
known as “interest-based advertisements.” You can learn more about your choices
for limiting interest-based advertising, in the Advertising choices section
below.

Compliance and protection. We may use your personal information to:

- comply with applicable laws, lawful requests, and legal process, such as to
respond to subpoenas or requests from government authorities.
- protect our, your or others’ rights, privacy, safety or property (including by
making and defending legal claims);
- enforce the terms and conditions that govern the Services; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized,
unethical or illegal activity, including cyberattacks and identity theft.

For other purposes. We may also use your personal information for other purposes
described in this Privacy Policy or at the time we collect the information.


HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as
otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes
consistent with this Privacy Policy.

Service providers. . Unrelated companies and individuals that provide services
on our behalf or help us operate the Service or our business (such as customer
support, hosting, payment processing, analytics, email delivery, marketing, and
database management services). These third parties may use your personal
information only as authorized under our contracts with them.

Partners. Third party partners who offer products and services that may be of
interest to you. We may sometimes share your personal information with partners
or enable partners to collect information directly via our Service, including
when you have indicated your interest in certain products or services.

Advertising partners. Third party advertising companies that collect information
about your activity on the Site and other online services to help us advertise
our and other services, and/or use hashed customer lists that we share with them
to deliver ads on their platforms to our customers and similar users (“Custom
Audience Campaigns”).

Third party platforms. Social media platforms or other third party platforms
that you connect to the Service and where you authorize us to share your
information with them (such as when you use options to access the Service by
logging into the third party platform).

Other users. Other users of the Service or the public when you chose to make
your profile or other personal information available to them through the
Service, such as when you provide comments, reviews, survey responses, or other
content. We do not control how other users or third parties use any personal
information that you make available to such users or the public. Please be aware
that any information you post publicly can be cached, copied, screen captured or
stored elsewhere by others (e.g., search engines) before you have a chance to
edit or remove it.

Professional advisors. Professional advisors, such as lawyers, bankers, auditors
and insurers, where necessary in the course of the professional services that
they render to us.

Authorities and others. Law enforcement, government authorities, and private
parties, when we believe in good faith it is necessary or appropriate for the
compliance and operations purposes described above

Business transferees. Relevant participants in business transactions (or
potential transactions) involving a corporate divestiture, merger,
consolidation, acquisition, reorganization, sale or other disposition of all or
any portion of the business or assets of, or equity interests in, HelloFresh or
our affiliates (including, in connection with a bankruptcy or similar
proceedings).

For other purposes. We may also share your personal information for other
purposes described in this Privacy Policy or with your consent.


YOUR CHOICES

You have the following choices with respect to your personal information:

Access or update your information. Updating Account Information. You may update
or edit your account information by accessing your account page at
www.hellofresh.com, accessing the account settings on your app, emailing
privacy@hellofresh.com, or calling toll free 1-844-242-2169. You may also
deactivate your account pursuant to the Terms and Conditions. We may retain
relevant information related to your account when permitted by law or for
legitimate business purposes.

Opt-out of marketing communications. You may opt out of marketing-related emails
by following the opt-out or unsubscribe instructions at the bottom of the email,
or by contacting us at privacy@hellofresh.com. You may opt out of receiving text
messages at any time by texting “STOP” to our text messages. You may continue to
receive service-related and other non-marketing emails.

Disclosure of your information for third party marketing. If you do not want us
to share your personal information with unaffiliated or non-agent third parties
for promotional purposes, you can opt-out by sending us an email stating your
request to privacy@hellofresh.com or calling toll free 1-844-242-2169.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the
instructions in your browser settings. Many browsers accept cookies by default
until you change your settings. Please note that if you set your browser to
disable cookies, the Service may not work properly. For more information about
cookies, including how to see what cookies have been set on your browser and how
to manage and delete them, visit www.allaboutcookies.org. To learn how you can
manage your Flash cookie settings, visit the Flash player settings page on
Adobe's website at
http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

Advertising choices. You may opt-out of receiving targeted online advertising on
websites through members of the Network Advertising Initiative at
http://www.networkadvertising.org/choices or the Digital Advertising Alliance at
http://www.aboutads.info/choices. You may opt out of receiving targeted
advertising in mobile apps through participating members of the Digital
Advertising Alliance in the AppChoices mobile app, available at
https://www.youradchoices.com/appchoices. Please note that we also may work with
companies that offer their own opt-out mechanisms and may not participate in the
opt-out mechanisms linked above. In addition, your mobile device settings may
provide functionality to limit use of the advertising ID associated with your
mobile device for targeted online advertising purposes. If you choose to opt out
of targeted online advertisements, you will still see advertisements online but
they may be less relevant to you. Not all companies participate in these opt-out
programs, so even after opting out through them, you may still receive some
cookies and interest-based from other companies.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track”
signals to the online services that you visit. We currently do not respond to
“Do Not Track” or similar signals. To find out more about “Do Not Track,” please
visit http://www.allaboutdnt.com.

Choosing not to share your personal information. If you do not provide
information that we need to provide the Service, we may not be able to provide
you with the Service or certain features. We will tell you what information you
must provide to receive the Service when we request it.

Third party platforms. If you choose to connect to the Service through your
social media account or another third party platform, you may be able to use
your settings in your account with that platform to limit the information we
receive from it. If you revoke our ability to access information from a third
party platform, that choice will not apply to information that we have already
received from that third party.


OTHER SITES AND SERVICES

The Service may contain links to websites and other online services operated by
third parties. These links are not an endorsement of, or representation that we
are affiliated with, any third party. In addition, our content may be included
on web pages or other online services that are not associated with us. We do not
control websites or other online services operated by third parties, and we are
not responsible for their actions. Other websites and online services follow
different rules regarding the collection, use and sharing of your personal
information. We encourage you to read the privacy policies of the other websites
and online services you use.


SECURITY PRACTICES

We employ a number of technical, organizational, and physical safeguards
designed to protect the personal information we collect. However, security risk
is inherent in all internet and information technologies and we cannot guarantee
the security of your personal information.


INTERNATIONAL DATA TRANSFERS

We are headquartered in the United States and may use service providers in other
countries. Your personal information may be transferred to the United States or
other locations where privacy laws may not be as protective as those in your
state, province, or country.


CHILDREN

Our sites and online services are not intended for use by children under 16
years of age. If we learn that we have collected personal information from a
child under 16 without the consent of the child’s parent or guardian as required
by law, we will delete it.


CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy at any time. If we make material changes to
this Privacy Policy, we will notify you by updating the effective date of this
Privacy Policy and posting the modified Privacy Policy on the Service. We may
also provide notification of changes via email if we have your email address,
through the Service or in another manner that we believe is reasonably likely to
reach you.

Any modifications to this Privacy Policy will be effective when posted (or as
otherwise indicated at the time of posting). In all cases, your continued use of
the Service after the posting of any modified Privacy Policy indicates your
acceptance of the modified Privacy Policy.


IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS

This section describes how we collect, use and share Personal Information of
California residents in operating our business, including in the context of
in-person meetings, at our events and other offline sales and marketing
activities. For purposes of this section, “Personal Information”” has the
meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does
not include information exempted from the scope of the CCPA.


YOUR CALIFORNIA PRIVACY RIGHTS. AS A CALIFORNIA RESIDENT, YOU HAVE THE RIGHTS
LISTED BELOW. HOWEVER, THESE RIGHTS ARE NOT ABSOLUTE, AND IN CERTAIN CASES WE
MAY DECLINE YOUR REQUEST AS PERMITTED BY LAW.

- You can request the following information about how we have collected and used
your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal
Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose,
and if so, the categories of Personal Information received by each category of
third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of
Personal Information sold to each category of third party recipient.
- Access. You can request a copy of the Personal Information that we have
collected about you during the past 12 months.
- You can ask us to delete the Personal Information that we have collected from
you.
- Opt-out of sales. If we sell your Personal Information, you can opt-out.
- You are entitled to exercise the rights described above free from
discrimination in the form of refusal to provide the Services or legally
prohibited changes to the price or quality of the Services.

How to exercise your rights You may exercise your California privacy rights
described above as follows:
- Right to information, access and deletion. You can request to exercise your
information, access and deletion rights by:
- clicking here and submitting a request form
- calling us toll free at 1-844-242-2169
- emailing privacy@hellofresh.com
- Right to opt-out of the “sale” of your Personal Information. Like many
companies, we use services that help deliver interest-based ads to you. Our use
of some of these services may be classified under California law as a “sale” of
your Personal Information to the companies that provide the services because
they collect information from our users (e.g., device data and online activity
data) to help them serve ads more likely to interest you. You can request to
opt-out out of this “sale” of your personal information here: Do Not Sell My
Personal Information

We reserve the right to confirm your California residency to process your
requests and will need to confirm your identity to process your requests to
exercise your information, access or deletion rights. As a part of this process,
government identification may be required. Consistent with California law, you
may designate an authorized agent to make a request on your behalf. In order to
designate an authorized agent to make a request on your behalf, you must provide
a valid power of attorney, the requester’s valid government-issued
identification, and the authorized agent’s valid government issued
identification. We cannot process your request if you do not provide us with
sufficient detail to allow us to understand and respond to it.

For information about:
- The categories of sources of this information, see the section above entitled
personal information we collect
- The business/commercial purposes for which we collect this information, see
the section above entitled how we use your personal information;
- The categories of third parties to which we disclose this information for
business purposes, see the section above entitled how we share your personal
information.





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