Privacy Policy

Last Updated: March 10, 2025

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Heritage Grocers Group, LLC and its affiliates and subsidiaries (collectively “HGG”“we,” “us,” or “our”) respect your privacy and are committed to protecting the privacy and security of personal information. This Privacy Policy (“Privacy Policy”) describes what Personal Information HGG collects, how that information is used, to whom it is disclosed, how it is safe guarded, and the choices you may have regarding the collection and use of such information.

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We collect data from users of our website heritagegrocersgroup.com (“Website”); from individuals who contact us online, by telephone or electronic means, or in person; from individuals who visit our facilities or operations; from individuals who attend events organized or hosted by us; from our customers or prospective customers (where these are natural persons) or their employees, agents, and representatives; and about others who express an interest in us or with whom we carry on business, including through our Website, our supermarkets and other facilities, and through our money services business; and from individuals who participate in any of our contests, sweepstakes, giveaways, or promotions (collectively, our Website and our foregoing activities and business operations are referred to in this Privacy Policy as our “Services” and the individuals about whom we collect data are referred to as “you” and “your”).

This Privacy Policy applies to Personal Information collected via the Services. Please note that this Privacy Policy does not apply to information collected strictly in the context of business-to-business relationships or transactions.

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This notice applies to information we collect:

On our Website.
On any website when you are submitting a job application or other document to us via the internet.
Through or as a result of your entry upon any of our facilities or in connection with our operations, or attendance at an event organized or hosted by us.
When you use or visit any of the Services.
From any paper submitted by you to us online.
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It does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on our Website.

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We are based in California. When we obtain Personal Information about you, we may transfer, process, and store such Personal Information in the United States. By using the Services, you consent to the transfer to, and to the processing and storage of such Personal Information in the United States.

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Please review this Privacy Policy carefully and, if you have any questions about it or our practices, please contact us as set forth in the Contact Us section below. By using or accessing the Services, you consent to and accept the terms set forth in this Privacy Policy. If you do not agree with our policies and practices, your choice is not to use our Website, our Services, or submit information to us. By accessing or using our Website or our Services and/or submitting information to us, you agree with this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website, the Services, and/or provision of information to us after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates .

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Collection of Information

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Information We Collect

The term “Personal Information” when used in this Privacy Policy means, in each case, information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, or device. In particular, HGG collects and has collected from its consumers within the last twelve (12) months the following categories of Personal Information:

Basic Identifying information: Personal identifiers you provide when you provide information for registration via our Website, When you visit our facilities or operations, or otherwise use the Services, including your first and last name, address, email address, telephone number, date of birth, or any personal identifiers you provide to us when communicating with us.
Internet connectivity, usage, and activity information about your use, and the use by any person(s) you authorize, of our Website, including the content you view, browser device and type, unique device identifier and/or Internet Protocol (IP) address, and information about your interactions with our Website including traffic patterns of the Website, and viewing of offerings on our Website.
Sensory data observed on general business security video surveillance at our facilities and operations and within our properties for the security and safety of our employees, customers, operations, assets, resources, and communities..
Demographic information, professional or employment-related information, work history, qualification/training information, education information, and any other information you choose to provide.
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We also capture anonymous information which means information that does not identify as specific individual through the use of cookies and website analytics:

Internet or other electronic network activity information, including, but not limited to, IP addresses, browsing history, search history, cookies, information about your interaction with our Website, and geolocation data.
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Personal information does NOT include:

Publicly available information from government records.
Deidentified or aggregated consumer information.

How We Collect Your Information

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We, or a service provider on our behalf, collect the categories of Personal Information about you via the information you voluntarily provide us when using or accessing the Services from the following categories of sources:

Directly from you. We collect information you provide to us when you apply for a job through our career portal; participate in, online programs, surveys, or other transactions or activities; communicate or otherwise interact with us through telephone, email or other electronic communication; through the use of our Website, the Services, our social media pages, or in person.
Indirectly from you. We collect information from you, your household, or devices associated with you or your household through your use and actions on our Website, persistent cookies on our Website, and third-party analytics for our Website, as well as publicly available sources of information.
In our facilities: we may collect Personal Information while you are in our facilities through our CCTV cameras which are used for safety, security, fraud and loss prevention, and other operational purposes.
Automated Collection Technologies: When you visit our websites or open our emails we and our third-party partners automatically gather certain information through online tracking technologies, including pixels, web beacons, software developer kits, third-party libraries, and cookies. These tools help us understand your interaction with our Services, detect and prevent fraud, perform analytics, enhance our Services, and carryout targeted advertising and marketing activities.
Other Sources: We may obtain your Personal Information from various sources, including public databases, social media platforms, data analytics service providers, data enrichment providers, consumer research providers, and other third parties (“Supplemental Information”). If we combine this Supplemental Information with the Personal Information collected under this policy, the combined data will be subject to the terms of this Privacy Policy for as long as it remains combined. To clarify, this Privacy Policy does not apply to Supplemental Information in its original form or any format that has not been merged with your Personal Information collected under this policy.

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Information Pertaining To Children

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The Services are not directed to, and we do not intend to, or knowingly, collect Personal Information online from, children under the age of 13. If we learn or have reason to suspect that a user of the Services is under the age of 13, we will promptly delete any Personal Information obtained from that user.

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Use of Personal Information

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We, or our service providers on our behalf, may use Personal Information for one or more of the following business purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, or communicate with us through email, our Website, our social media pages, or by telephone, we will use that Personal Information to respond to your requests or inquiries and communicate with you.
To have a means of communicating with you about transactions with us and send you information or request feedback about your purchases, the Services, and features on our Website, or changes to our policies..
If you submitted your Personal Information in connection with a job application, evaluating that application and related materials you submit or that we are able to obtain, including for purposes of reference checking, in connection with making an employment decision.
Managing and improving the Services’ ongoing operation, including maintaining the security of the Services.
Tracking information about usage trends and user activities online over time and conducting analytics to improve the Services’ operation and services.
Creating aggregated or anonymized information for analytical and statistical purposes.
Complying with applicable law or legal process(e.g., a search warrant, subpoena, or court order).
Verifying and validating your identity or otherwise detecting, preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or activities that may violate our policies.
Enforcing our agreements and protecting or defending our rights.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

HGG will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

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Disclosure of Personal Information

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HGG does not sell your Personal Information to any third parties for any monetary or commercial benefit and has not sold your Personal Information in the past twelve (12)months, for any monetary or commercial benefit.

We may disclose Personal Information described above to our affiliates and certain third parties (including regulatory bodies or service providers) under one or more of the circumstances described below:

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As Required by Law – if we are required by applicable law to disclose the information;

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As Authorized – if you request or authorize the disclosure of the information; and

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To Service Providers– if we use service providers, such as (i) social media platforms (e.g., Facebook, Instagram, YouTube or Twitter) integrated into the Services, (ii) the online career portal (such as ADP, Law Logix, LinkedIn or Talent Reef), (iii) analytics providers, (iv)sweepstakes or contest management platforms (e.g., Short Stack or International Scholarship and Tuition Services)or apps, (v) market researchers, (vi) email subscription management platforms and applications (e.g., Flipp or Mail Chimp),(vii) third-party data centers and storage providers or (viii) other service providers engaged to perform services on our behalf (including web hosting and mobile messaging administration ). All Personal Information you provide to such service providers is subject to the privacy policy or notice of such service providers. We may also share your personal information with third parties in accordance with contractual arrangements in place with them.

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As Part of Certain Business Transfers – We may disclose Personal Information in connection with a corporate business transaction, such as a potential or consummated merger, acquisition, or joint venture, or for the financing or sale of our assets and could be transferred to another party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy, or receivership.

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As Permitted by Law – We may also disclose Personal Information in other circumstances, including to law enforcement or other government agencies, tax authorities, applicable regulators (or in response to requests from such parties), in the context of litigation or when we otherwise believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates law

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Security of Personal Information

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We restrict access to Personal Information in our possession solely to those employees, subsidiaries or affiliates of HGG who need to know that information to provide services to you and may disclose Personal Information to third parties as set out above. We require that these entities otherwise keep this information confidential, handle it in accordance with applicable law and implement appropriate technical and organizational measures to protect it. We maintain physical, electronic, and procedural safeguards that comply with applicable laws and regulations to guard Personal Information. The transmission of information via the Internet is not completely secure and we cannot guarantee the absolute security of our servers or databases or those of our service providers. Your use or access of the Services and any transmission of Personal Information through the Services is at your own risk.

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Our Website May Have Third Party Links

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Our Website may have links to third-party content. We do not control that content or the third party’s privacy practices. We encourage you to read their privacy policies to understand how they use your information.

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Your Privacy Rights

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We process all Personal Information described above to the extent required by and in accordance with applicable law (including in accordance with any applicable time limits).You may have certain rights in relation to such Personal Information, depending on where you live.

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Residents of the State of California

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The information in this section is directed only to those users that reside in California.

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The California Consumer Privacy Act of 2018 (CCPA) provides California residents who are “consumers,” as defined in the CCPA, with specific rights regarding their Personal Information. This section of this Privacy Notice describes the rights of “consumers,” as defined in the CCPA, and explains how California consumers can exercise those rights (“CCPA Privacy Notice”). Any terms defined in the CCPA have the same meaning when used in this CCPA Privacy Notice. Consumers with disabilities may access this CCPA Privacy Notice in an alternative format by contacting HGG through any one of the methods set forth below.

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Residents of California have certain rights in regards to the personal information collected by HGG:

Right to access the data collected by HGG
Right to opt out of the sale or future sale of personal data collected by HGG
Right to know whether HGG has collected any data
Right to know if any data has been sold by HGG
Right to delete their personal data held by HGG, subject to restrictions
Right to correct incomplete or inaccurate personal data held by HGG
Right to receive a copy of personal data in a reasonable format
Right to limit the use and disclosure of sensitive personal information
Right to access information about automated decision-making to request information about automated decision-making (e.g. AI tools) and likely outcomes of using such processes, particularly with regards to profiling
Right to opt out of the use of automated decision-making technology with regard to their personal data

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Right to Request Disclosure About the Personal Information Collected About You

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Employees have the right to request that HGG disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we have received and verified your request, we will disclose to you:

(i) The categories of your Personal Information we have collected;
(ii) The categories of sources from which we collect your Personal Information;
(iii) The business or commercial purpose for collecting your Personal Information;
(iv) The categories of third parties with whom we share your Personal Information;
(v) The specific pieces of your Personal Information we have collected (also called a data portability request); and
(vi) If we disclosed your Personal Information for a business purpose, a list of the categories of Personal Information we have disclosed in the prior 12 months.

However, HGG will not at any time in response to a request disclose a consumer’s financial account number or an account password, or security questions and answers.

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HGG is not required to retain any Personal Information collected for a single, one-time transaction, if the information is not regularly retained by HGG, or re-identify any anonymous or de-identified information, in order to disclose that information to you.

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We do not sell Personal Information.

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Deletion Request Rights

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Consumers, as defined in the CCPA, have the right to request that HGG delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we have received and verified your identify and request, we will delete your Personal Information from our records, unless an exception applies.

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We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

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2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

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3. Debug products to identify and repair errors that impair existing intended functionality.

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4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

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5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et. seq.).

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6. 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

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7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

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8. Comply with a legal obligation.

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9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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Exercising Access and Deletion Rights

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If you are a California resident and you wish to exercise your rights to access the information HGG has collected about you and/or request that HGG delete the information about you, you will need to submit a verifiable consumer request so that HGG is able to corroborate your identity and provide your information to you.

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You may submit requests for access or deletion to us via the methods set forth in the Contact Us section below. We will respond to your requests within the applicable time periods and in the manner prescribed by the CCPA.

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Only you, or a person registered with the California Secretary of State that is authorized by you to act on your behalf, may submit a request for access to, or deletion of, Personal Information.

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You may only make a verifiable consumer request for access or data portability 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 Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Any request to delete submitted through an online request will require you first to submit the request and, second, separately confirm that you want the information deleted.

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Non-Discrimination

We will not deny services, charge different prices, offer a different quality of service or otherwise discriminate against an individual for exercising the rights afforded to him or her under the CCPA.

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Some browsers may transmit “do-not-track” (“DNT”) signals to mobile applications with which the user communicates. We currently do not change our tracking practices in response to DNT settings in your browser. We may have our third-party service providers, as discussed above, collect information about your online activities over time. These third parties may not change their tracking practices in response to DNT settings in your browser.

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Residents of the State of Nevada

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The information in this section is directed only to those users that reside in Nevada. Under Nevada Revised Statutes Chapter 603A, individuals who are residents of Nevada and whose Personal Information we collect and process may have certain legal rights with respect to such Personal Information.

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You may submit requests to review or correct any Personal Information that we have collected through the Services via the methods set forth in the Contact Us section below. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

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Nevada residents who wish to exercise their right to opt-out of the sale of their Personal Information under Nevada Revised Statutes Chapter 603A may submit a request to the designated addresses set forth in the Contact Us section below. We do not, however, sell any Personal Information.

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Retention

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We endeavor to ensure that Personal Information is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. We will retain Personal Information for as long as we determine is required to satisfy the purpose for which we, or a third party on our behalf, collected it or you provided it to us, subject to your right, under certain circumstances, to have certain of such Personal Information erased (see Your Rights above), unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights subject to any statutory limitation. We may decide to retain some Personal Information for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.

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Updates to this Privacy Policy

This Privacy Policy is subject to occasional revision. If we make any material changes in the way we use Personal Information, including if we intend to use Personal Information that we collected for one purpose for any other purpose not otherwise permitted by this Privacy Policy, we will either notify you of such changes via email and post the updated Privacy Policy on this page or, where required by law, we will obtain your express consent to use Personal Information for such other purpose. Changes to this Privacy Policy will be effective immediately upon posting. Your use of the Services after the posting of such changes will bind you to the Privacy Policy as so amended.

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Contact Us

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If you have any questions, comments, requests or concerns about this Privacy Policy or other privacy-related matters, or wish to exercise your rights under California law, you may contact us at:

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Heritage Grocers Group, LLC

2501 East Guasti Rd. Ontario,CA 91761

Privacy Inquiries:http://www.lighthouse-services.com/heritagegrocers/privacy

Toll-free Number: (855) 550-0007

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In connection with any privacy-related requests you submit to us in exercising rights to which you are entitled under applicable law, we will undertake steps to verify your identity. We may ask you to provide information that we have in the file about you or, if the request is submitted in writing or electronically, we may contact you via another method(e.g., telephone) to verify your identity. We will only use Personal Information provided in a request to verify the requestor’s identity and authority to make the request and we will maintain a record of any such requests as required by law.

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