Last Updated: April 1, 2023

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the Trade Coffee Privacy Policy (the “Privacy Policy”) made available on the website located at www.drinktrade.com (the “Site”). The Site is owned and operated by Seed Leaf Inc., d/b/a Trade (“Trade,” “we,” “us” or “our”). This Privacy Notice applies solely to residents of the State of California (including California-based employees of, and California residents who submit job applicants to, Trade), as well as businesses organized under the laws of the State of California (“CA Users”). We adopt this Privacy Notice in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) , the California Privacy Rights Act of 2020 (“CPRA”), and other applicable California State privacy laws. Any terms defined in the CCPA and/or CPRA have the same meaning when used in this Privacy Notice. Please note that this Privacy Notice is incorporated into the Terms of Service (“Terms”) for Trade and, unless we otherwise define a term in this Privacy Notice, a capitalized term used in this Privacy Notice has the meaning set forth in the Terms.

Users with disabilities who wish to access this Privacy Notice in an alternative format can contact us by: emailing us at: support@tradecoffeeco.com; calling us at: +1(888) 252-8691; or sending us U.S. Mail to: Trade Coffee Co., 85 Broad St., Suite 09-012, New York, NY 10004.

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver's license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a CA User's interaction with a website, application or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privac Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive Personal Information.	A Social Security number, driver’s license number, state identification card number, or passport number. Account log-in information, financial account, or debit or credit card number used in combination with any required security code, access code, password, or log-in credentials necessary to access an account. Precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer’s U.S. mail, electronic mail, or text messages unless the business is the intended recipient, and a consumer’s genetic data.	YES

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated CA User information.
• Information excluded from the CCPA's scope, such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

• Directly from our CA Users. For example, from online registration forms that our CA Users submit to us in connection with the products and/or services that we offer by and through the Site and/or Service. (Categories A, B, C, D and L)
• Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Categories A, B, C, D, F and L)
• Directly and indirectly from activity on the Site and/or associated with the Service. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Site/Service usage details and analytics as same are collected automatically by us and our third party partners, such as Crazy Egg, Datadog, Facebook®, Google® and Retention.com. (Category F)
• When our CA Users interact with us on our Social Media Website accounts, including commenting on and/or liking our posts. (Category F)
• From third-parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Categories A, B, C, D, F and L)

Use of Personal Information

We may use or disclose the personal information that we collect for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your purchase of products and/or services, we will use that information to process your order. (Categories A, B, C, D, F and L)
• To provide you with information, products or services that you request from us. (Categories A, B, C, D, F and L)
• To create, maintain, customize and secure your account with us. (Categories A, B, C, D, F and L)
• To provide you with e-mail, direct mail and telemarketing messages concerning certain Trade products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Categories A, B, C, D and F)
• To deliver relevant Site/Service content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Categories A, B, C, D and F)
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Terms. (Categories A, B, C, D, F and L)
• To improve the Site and Service, and better present their respective contents to you. (Categories A, B, C, D and F) For customer service purposes and to respond to inquiries from you. (Categories A, B, C, D and L)
• For testing, research, analysis and product development. (Categories A, B, C, D and F)
• As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Categories A, B, C, D, F and L) To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Categories A, B, C, D, F and L)
• As described to you when collecting your personal information or as otherwise set forth in the CCPA and/or CPRA. (Categories A, B, C, D, F and L)
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Categories A, B, C, D, F and L)

We 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 with notice.

Data Retention We retain personal information, certain communications with you, and analytics generated by the operation of our Service (collectively, the “Service Output”), as long as we believe it is necessary and relevant for the operation of our Service. Our Service operates on computers owned and/or operated by Trade and located in third-party data centers in the United States and, possibly in other countries in the future.

Under certain circumstances we may retain personal information after the termination of a Customer account. We do this to ensure that the Service is not interrupted and none of the Service Output is lost due to interrupted Service subscriptions or other unanticipated events. We may also retain personal information after a Customer account is terminated to prevent fraud, collect any payments owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms, comply with applicable legal data retention obligations and take other actions permitted by law.

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale (as permitted by applicable law, including restrictions on sharing Sensitive Personal Information), we may share, rent and/or sell your personal information from Categories A, B, C, D, F and L: (a) with/to third parties for marketing purposes (but not Sensitive Personal Information); and (b) for the other business purposes set forth above.

We share your Sensitive Personal Information with the following third parties: PayPal Holdings, Inc. (“PayPal®”) and Stripe, Inc. (“Stripe®”). These third party entities collect credit card information from users in connection with processing purchases made by and through the Site. Trade requires that its third party payment processing service provider(s) has/have in place privacy policies and practices consistent with the Privacy Policy; provided, however, that we cannot guarantee the privacy practices of our third party payment processing service provider(s) including, without limitation, Stripe® and PayPal®. These payment processors may use your payment data in accordance with their privacy policies. Stripe’s® privacy policy is available at https://stripe.com/privacy and PayPal’s® privacy policy is available at paypal.com/myaccount/privacy/privacyhub.

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Category A Identifiers.
• Category B Personal information categories listed in the California Customer Records statute.
• Category C Protected classification characteristics under California or federal law.
• Category D Commercial information.
• Category F Internet or other similar network activity.
• Category L Sensitive Personal Information.

We disclose your personal information for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):

• Our affiliates. (Categories A, B, C, D, F and L)
• Service providers. (Categories A, B, C, D, F and L) Third parties who provide certain of the products and/or services featured on the Site and/or by and through the Service. (Categories A, B, C, D and F)
• Only where you expressly opt-in to such use, third parties who purchase and/or license your personal information for marketing purposes, including: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers (Categories A, B, C, D and F).
• Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. (Categories A, B, C, D, F and L)

In the preceding twelve (12) months, we have sold the following categories of personal information to third parties:

• Category A Identifiers.
• Category B Personal information categories listed in the California Customer Records statute.
• Category C Protected classification characteristics under California or federal law.
• Category D Commercial information.
• Category F Internet or other similar network activity.

In the preceding twelve (12) months, we have sold the above referenced categories of personal information (but not Sensitive Personal Information) to the third parties who purchase and/or license your personal information for marketing purposes, as well as the third parties who provide the products and/or services featured on the Site and/or by and through the Service.

Your Rights and Choices

The CCPA and CPRA provide CA Users (California residents) with specific rights regarding their personal information. This section describes your rights under the CCPA and CPRA and explains how to exercise those rights.

Do Not Sell My Personal Information

You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:

• Clicking here;
• Calling us at: (888) 252-8691;
• Emailing us at: support@tradecoffeeco.com; or
• Sending us U.S. Mail to: Trade Coffee Co, 85 Broad St., Suite 09-012, New York, NY 10004.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.

Opt-Out from the Sharing of Your Personal Information

You have the right to opt-out of our sharing your personal information with third parties. To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable Covered User request to us by either:

• Clicking here;
• Calling us at: (888) 252-8691;
• Emailing us at: support@tradecoffeeco.com; or
• Sending us U.S. Mail to: Trade Coffee Co, 85 Broad St., Suite 09-012, New York, NY 10004.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request. Subject to the aforementioned fifteen (15) business day period, where we receive and confirm your verifiable opt-out request, we will cease sharing your Personal Information with third parties.

Opt-Out from the User and/or Sharing of Your Sensitive Personal Information

You have the right to limit our use of your sensitive personal information, including any sensitive information from Category B (Personal information categories listed in the California Customer Records statute), Category C (Protected classification characteristics under California or federal law), Category D (Commercial information) and/or Category L (Sensitive Personal Information), to those uses which: (i) are necessary to perform the services or provide the goods requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site; (iv) involve performing services on behalf of Trade, 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 behalf of Trade; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned by, manufactured by, manufactured for, or controlled by, Trade, and to improve, upgrade, or enhance the service or device that is owned by, manufactured by, manufactured for, or controlled by, Trade.

You also have the right opt-out of our sharing your sensitive personal information with third parties, including any sensitive information from Category B (Personal information categories listed in the California Customer Records statute), Category C (Protected classification characteristics under California or federal law), Category D (Commercial information) and/or Category L (Sensitive Personal Information).

To exercise your right to limit our use of your sensitive personal information and/or opt-out of our sharing your sensitive personal information with third parties, please submit a verifiable Covered User request to us by either:

• Clicking here;
• Calling us at: (888) 252-8691;
• Emailing us at: support@tradecoffeeco.com; or
• Sending us U.S. Mail to: Trade Coffee Co, 85 Broad St., Suite 09-012, New York, NY 10004.

We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request. Subject to the aforementioned fifteen (15) business day period, where we receive and confirm your verifiable opt-out request, we will cease using your Sensitive Personal Information/sharing your Sensitive Personal Information with third parties (and direct our service providers and contractors to do the same).

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we have shared that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Subject to the time period allotted to comply with such requests, where we receive and confirm your verifiable CA User deletion request, we will delete (and direct our service providers, contractors and third parties to whom we sold/shared your personal information, to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.

We may deny your deletion request if retaining the information is necessary for us or our service providers, contractors and/or third parties to whom we sold/shared your personal information, to:

• 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 obligations in connection with our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech rights, ensure the right of another CA User to exercise her/his free speech rights or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• 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, but only if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Request Correction of Inaccurate Personal or Sensitive Personal Information

You have the right to request correction of inaccurate personal and/or sensitive personal information that we collect. Upon receiving a verifiable consumer request for correction, we will make commercially reasonable efforts to correct information identified as inaccurate. Where we correct inaccurate personal and/or sensitive personal information, we shall instruct all service providers and/or contractors that maintain such personal and/or sensitive personal information in the course of providing services to us to make the necessary corrections in their respective systems.

Exercising Access, Data Portability and Deletion Rights

To exercise your access, data portability, right to correct and/or deletion rights described above, please submit a verifiable CA User request to us by either:

• Clicking here;
• Calling us at: (888) 252-8691;
• Emailing us at: support@tradecoffeeco.com; or
• Sending us U.S. mail to: Trade Coffee Co, 85 Broad St., Suite 09-012, New York, NY 10004.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:

• Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 that the personal information relates to you. Making a verifiable CA User request does not require that you create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User access, data portability, right to correct and/or deletion rights requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response that we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Authorized Agents

Users may permit an Authorized Agent to exercise any rights granted under the CCPA and CPRA as set forth above. Any individual acting on your behalf as an agent must register with the California Secretary of State. Further, in order to utilize an Authorized Agent, you must provide the Authorized Agent with written permission from you to act on your behalf for these purposes. When you use an Authorized Agent to submit a request to opt-out, request to delete, request to limit, request to correct or a request to know, we may require the Authorized Agent to provide proof that you gave the agent signed permission to submit the subject request. We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the Authorized Agent permission to submit the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; and/or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to these Privacy Provisions

We reserve the right to amend this Privacy Notice in our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on the Site’s homepage/on the applicable Service user interface.

Contact Information

If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:

• Clicking here;
• Calling us at: (888) 252-8691;
• Emailing us at: support@tradecoffeeco.com; or
• Sending us U.S. mail to: Trade Coffee Co, 85 Broad St., Suite 09-012, New York, NY 10004.