California Privacy Statement

This California Privacy Statement (“Statement”) supplements the Smithfield Privacy Policy. It applies to California residents, including our customers, Site visitors, business customers, business partners, vendor representatives, and job applicants, and addresses personal information we collect online and offline. This Statement does not apply to Smithfield personnel.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We may collect (and may have collected during the 12-month period prior to the Last Updated date of this Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, marital status, medical condition, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, and similar information
• Employment Information: professional or employment-related information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We may use (and may have used during the 12-month period prior to the Last Updated date of this Statement) the categories of personal information listed above for the purposes described in our Privacy Policy and the following business purposes specified under the CCPA:

• Performing services, 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 our behalf.
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us.
• Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance a service or device that is owned, manufactured, manufactured for, or controlled by us.
• Providing advertising and marketing services, except for cross-context behavioral advertising (which is addressed in the “Sale or Sharing of Personal Information” section of this Statement).
• Managing career opportunities with us.
• Managing our relationships with current or prospective corporate customers, vendors and other business partners.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

We do not use or disclose (and have not used or disclosed during the 12-month period prior to the Last Updated date of this Statement) “sensitive personal information” (as defined under the CCPA) for any purpose other than those expressly permitted under the CCPA.

SOURCES OF PERSONAL INFORMATION

During the 12-month period prior to the Last Updated date of this Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you (such as when you participate in (or register on our Sites for) promotions, offers, programs, contests, sweepstakes or other participatory events; communicate with us; purchase goods from us; or apply for employment with us)
• From your devices (such as when you browse or use our Sites)
• Your family or friends (such as when they contact us on your behalf, or refer you for one of our contests, sweepstakes or other participatory events)
• Our subsidiaries and other brands or businesses in the Smithfield family of companies
• Vendors who provide services on our behalf
• Our business partners (such as our licensees, franchisees and promotional partners)
• Corporate customers (such as when they refer complaints and inquiries to us or provide mail-to lists for gift purchases)
• Social networks
• Advertising networks and agencies
• Data aggregators
• Data brokers
• Data analytics providers
• Internet service providers
• Operating systems and platforms
• Government agencies, courts and regulators
• Public databases
• For job applicants, recruiting and talent agencies
• For job applicants, job references, such as your employers
• For job applicants, credit reporting and background check service providers

RETENTION OF PERSONAL INFORMATION

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in this Statement or our Privacy Policy, or any other notice provided at the time of data collection, taking into account applicable statutes of limitation and records retention requirements under applicable law, as well as our records retention requirements and policies.

SALE OR SHARING OF PERSONAL INFORMATION

We do not sell your personal information in exchange for monetary compensation. As described in our Privacy Policy, we may disclose or make available your personal information by allowing certain third parties (such as providers of online advertising or data analytics services and social networks) to obtain your personal information, including via automated technologies on our Sites. We may disclose your personal information to such third parties for analytics purposes or for the enhanced ability to serve you content and advertisements that may be of interest to you.  Under the CCPA, this type of disclosure may be considered a “sale” when the personal information is exchanged for non-monetary consideration, or “sharing” when the personal information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these disclosures of your information as described in the “California Privacy Rights” section below.

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Updated date of this Statement) the following categories of personal information to providers of online advertising or data analytics services and social networks: Identifiers, Commercial Information, Online Activity and Inferences.

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

DISCLOSURE OF PERSONAL INFORMATION

During the 12-month period prior to the Last Updated date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this Statement, we may have disclosed personal information about you to government entities, such as law enforcement or regulatory agencies, and third parties in connection with corporate transactions, such as mergers, acquisitions and divestitures.

6. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have certain choices regarding your personal information, as described below, subject to certain exceptions under applicable law.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold or shared about you, including the categories of personal information collected, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.  To submit an access request, click here.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate. To submit a correction request, click here.
• Deletion: You have the right to request that we delete personal information we have collected from you.  To submit a deletion request, click here.
• Opt-Out of Sale or Sharing: You have the right to opt out the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes. To submit an opt-out of sale or sharing request, click here or use the Global Privacy Control signal. If you would like to opt-out of the sale or sharing of your personal information associated with a different device or browser, please submit an opt-out request or broadcast the Global Privacy Control signal using that device or browser. Please note that if you clear your cookies on a particular browser or device, you may need to resubmit your opt-out request again from that device or browser. Requests sent using the Global Privacy Control will apply to the device and browser from which they are submitted.  For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org/.  
• Shine the Light Request: You may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. You also may ask us to refrain from sharing your information with certain affiliates and other third parties for their own marketing purposes.  To submit a Shine the Light request, email us at privacypolicy@smithfieldfreshmeats.com.

To submit a request to exercise any of the rights above as an authorized agent on behalf of an individual, please email us at privacypolicy@smithfieldfreshmeats.com.

VERIFYING REQUESTS

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion or correction request. We may verify your identity by requiring you to provide information to help us identify you, depending on the nature of your relationship with Smithfield, including name, address, phone number, email address, and purchase-related information. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If you designate an authorized agent to make an access, correction, deletion, or opt-out of sale or sharing request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access, correction and deletion requests, we may require you to verify your own identity directly with us.

ADDITIONAL INFORMATION

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacypolicy@smithfieldfreshmeats.com if you have any questions or concerns about our privacy policies and practices, or to request this Statement in an alternative format.