Privacy Policy

Effective Date: May 01, 2023

This Privacy Policy of Seed Leaf Inc. d/b/a Trade (“Trade”) applies to information that Trade obtains from its websites, including the Trade Coffee Co. site located at www.drinktrade.com (the “Site”) and its featured services (collectively, the “Service”), as well as the information you may provide to us via other means of communication.

We respect your privacy and will strive to protect your personal information. This Privacy Policy describes how Trade collects, uses, shares and secures the information you provide. It also describes choices you may make regarding use, access and correction of your personal information. Please note that this Privacy Policy is incorporated into our Terms of Service (“Terms”) for Trade and, unless we otherwise define a term in this Privacy Policy, a capitalized term used in this Privacy Policy has the meaning set forth in the Terms.

You agree that by using the Service you acknowledge that you have read and consent to the collection, use and sharing of your information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you are not permitted to access and/or use the Service. This Privacy Policy does not apply to websites not operated by Trade, including any to which the Service provides a link or which link to the Service. Please note, if you are a resident of a European Union Member State, you are not permitted to access and/or use the Service.

Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us by emailing us at: support@tradecoffeeco.com ; by 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.

STATE SPECIFIC PRIVACY RIGHTS

Residents of the States of California, Colorado, Connecticut, Utah and Virginia, California and Colorado-based employees of Trade, residents of the States of California and/or Colorado who submit job applicants to Trade, as well as businesses organized under the laws of the State of California (collectively, “Covered Users”), are afforded additional rights pursuant to applicable state law. Please see our "Privacy Provisions for Covered Users" below for a more complete description of your rights as a Covered User.

1. Your California Privacy Rights

Shine the Light. If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, please e-mail us at: support@tradecoffeeco.com; send us U.S. Mail to: Trade Coffee Co, 85 Broad St., Suite 09-012, New York, NY 10004; or call us at: +1(888)252-8691.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at: support@tradecoffeeco.com; send us U.S. Mail to: Trade Coffee Co, 85 Broad St., Suite 09-012, New York, NY 10004; or call us at: +1(888)252-8691. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

California Consumer Privacy Act of 2018 (“CCPA”). In addition to the foregoing, if you are a resident of the State of California, certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to opt-out of our sale of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the CCPA as a California State resident.

The California Privacy Rights Act (“CPRA”). In addition to the foregoing, if you are a resident of the State of California, certain other privacy-related rights may apply to you in accordance with the CPRA, including the right to correct personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to know how long we retain your sensitive and non-sensitive personal information, the right to know what sensitive personal information about you we have collected, whether your sensitive personal information was shared with third-parties in the preceding year and, if so, what categories of sensitive personal information were shared, as well as the categories of third parties with whom we shared that sensitive personal information. Please see our "Privacy Provisions for Covered Users" below for a more complete description of your rights under the CPRA as a California State resident.

Browser "Do Not Track" Signals. Most browsers contain a "do-not-track" setting. In general, when a "do-not-track" setting is active, the user’s browser notifies other websites that the user does not want her/his personal information and online behavior to be tracked and used, for example, for interest-based advertising. As required by California Online Privacy Protection Act ("CalOPPA"), we are required to inform you that, as is the case with most websites, we do not honor or alter our behavior when a Site user has activated the "do-not-track" setting on her/his browser; provided, however, that you may have certain rights with respect to the use of automated technologies to deliver targeted advertising to you, as well as to create profiles of you using your personal information.

2. Your Colorado Privacy Rights

If you are a resident of the State of Colorado, certain privacy-related rights may apply to you in accordance with the Colorado Privacy Act (“CPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our "Privacy Provisions for Covered Users" below for a more complete description of your rights under the CPA as a Colorado State resident.

3. Your Connecticut Privacy Rights

If you are a resident of the State of Connecticut, certain privacy-related rights may apply to you in accordance with the Connecticut Data Privacy Act (“CDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our "Privacy Provisions for Covered Users" below for a more complete description of your rights under the CDPA as a Connecticut State resident.

4. Your Nevada Privacy Rights

Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any "covered information" that the website operators have collected about Nevada State residents to any third party data broker(s). Covered information includes a consumer’s name, postal and email address, telephone number and Social Security Number, and includes the Information described below in the "Personal Information that We Collect" section.

If you are a Nevada State resident and you wish to exercise your right to request that we to stop the sale of your Information to third party data brokers, please e-mail us at: support@tradecoffeeco.com; call us at: +1(888)252-8691; or send us U.S. Mail to: Trade Coffee Co, 85 Broad St., Suite 09-012, New York, NY 10004. In your request, please specify that you want to exercise your rights to opt-out from the sale of covered information under the Nevada Privacy Law and specify the website that you visited and the email address you registered with. Please allow thirty (30) days for a response.

5. Your Virginia Privacy Rights

If you are a resident of the State of Virginia, certain privacy-related rights may apply to you in accordance with the Virginia Consumer Data Protection Act (“VCDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our "Privacy Provisions for Covered Users" below for a more complete description of your rights under the VCDPA as a Virginia State resident.

6. Your Utah Privacy Rights

If you are a resident of the State of Utah, certain privacy-related rights may apply to you in accordance with the Utah Consumer Privacy Act (“UCPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our "Privacy Provisions for Covered Users" below for a more complete description of your rights under the UCPA as a Utah State resident.

GENERAL PRIVACY PROVISIONS

PRIVACY POLICY QUICK LINKS
Below are links to key sections of our Privacy Policy:

MODIFICATION OF THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time, as new features, technology, or legal requirements arise. You may always determine if this Privacy Policy has changed by checking the Effective Date at the top of this page. If we make a significant change, we’ll notify you and, where required, seek your consent. If we update this Privacy Policy, you are free to decide whether to accept the updated terms or to stop using the Service. Your continued use of the Service after the effectiveness of that update will be deemed to represent your consent to the provisions in the updated Privacy Policy.

INFORMATION COLLECTED

Please see our Provisions for Covered Users below for additional details regarding the categories of personal information collected.

Customer Provided Information

We may collect and store any personal information you provide on the Site, via the Service, or in some other manner. When we refer to "personal information" in this Privacy Policy, we mean information that can be associated with a specific person and could be used to identify that specific person whether from that data alone or from that data in combination with other information that we have access to, as well as any other data determined to be personal information under any and all applicable U.S. privacy laws. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person. Personal information includes Customer Information, such as your name, address, email address, telephone number, billing and shipping addresses and financial information such as your payment method (valid credit card number, type, expiration date or other financial information). In addition, if you choose to use certain features of the Service, we may require you to provide additional personal information, such as shopping preferences and demographics. For purposes of this Privacy Policy, payment method information (such as credit card number or other financial information) will be considered “Sensitive Personal Information.”

We may also collect and store personal information that you provide to us about other people. If you use our Service to send others (friends, relatives, colleagues, etc.) a Gift Card, a product, information that may interest them or messages (such as invitations) through our system, we may store your personal information and the personal information of each such recipient.

Automatically Collected Information/Cookies

We automatically collect information from your browser when you visit the Site and/or use the Service. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us and the referring website address.

When you visit the Site and/or use the Service, we may assign your computer one or more cookies to facilitate access to the Site and/or Service, as applicable, and to personalize your online experience. Through the use of a cookie, we may automatically collect information about your online activity on the Site and/or in connection with the Service, such as the web pages you visit, the links you click on and the searches you conduct on the Site and/or in connection with the Service. A cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. To find out more about cookies, please visit www.cookiecentral.com. We use cookies to improve the quality of the Service, including for storing user preferences. We may use standard Internet technology, such as web beacons, tracking pixels and other similar technologies, to track your use of the Site. We also may include web beacons in email messages or newsletters to determine whether messages have been opened and acted upon. We may use standard Internet technology, such as web beacons, tracking pixels and other similar technologies, to track your use of the Site. We also may include web beacons in email messages or newsletters to determine whether messages have been opened and acted upon.

We may use third-party advertising companies to help tailor content or to serve ads on our behalf. These companies may employ cookies and web beacons to measure advertising effectiveness (such as which web pages are visited or what products are purchased and in what amount). Any information that these third parties collect via cookies and web beacons is not linked to any personal information collected by us.

Behavioral Tracking/Marketing

We may use third-party advertising companies to help tailor content, improve our offerings and to serve targeted ads on our behalf, and on behalf of those third-parties. These companies may employ cookies, web beacons and other tracking technology to track your activities on the Site and/or in connection with the Service, to measure advertising effectiveness (such as which web pages are visited or what products are purchased and in what amount).

Without limiting the foregoing, we may use a tool called “Google Analytics®” on the Site. We may combine the information collected through the use of Google Analytics® with your personal information, and we and/or Google® may use that information to serve you targeted ads after you leave the Site. Google’s® ability to use and share information collected about your visits to (and use of) the Site and/or in connection with the Service through the Google Analytics® tool is restricted by the Google Analytics® Terms of Service, available here, and the Google® Privacy Policy, available here. You may learn more about how Google® collects and processes data specifically in connection with Google Analytics® here. You may prevent your data from being tracked and/or used by Google Analytics® by downloading and installing the Google® Analytics Opt-out Browser Add-on, available here.

We may also use a web analysis tool called Facebook Analytics®. We may combine the information collected through the use of Facebook Analytics® with your personal information, and we and/or Facebook® may use that information to serve you targeted ads after you leave the site. Facebook Analytics’® use of information and privacy policy can be found here.

We may also use a tool made available by GetEmails, LLC d/b/a Retention.com (“Retention.com”). When you visit our website, log in, register or open an email, cookies, ad beacons, we may use the Retention.com tool to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting here.

Trade also uses Datadog® to monitor Site-User sessions to help us optimize Site functionality. Datadog® collects User information on a non-personally identifiable basis. For further details, including opt-out methods, please see Datadog’s® privacy policy by clicking here.

Further, Trade uses Crazy Egg® to monitor Site-User sessions to help us optimize Site functionality. Crazy Egg® collects User information on a non-personally identifiable basis. For further details, including opt-out methods, please see Crazy Egg’s® privacy policy by clicking here.

In general, users may be able to disable some, or all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative.

Network Advertising Initiative or Digital Advertising Alliance

Information from Other Sources

We may also periodically obtain both personal and non-personal information about you from our business partners, contractors and other third parties, and we may add such information to our account information or other information we have collected. In addition, if you access the Service using log-in credentials from another website or service (for example, Google or Facebook), we may obtain both personal and non-personal information from such other website or service, which you may review and adjust within such other services.

Cross Device Tracking

Trade tracks users’ use of the Service across multiple devices, including personal computers and mobile devices.

LIVE CHAT/CHAT BOTS

Trade utilizes third-party service providers to provide live chat and automated chat services (collectively, “Chat”) to Users on the Site. These third party Chat service providers, including Kustomer, LLC, may collect and store the content of these Chat conversations, and will share same with Trade; provided, however, that these third-party Chat service providers are not permitted to utilize User personal information collected via Chat conversations for any purpose other than: (a) to provide the Chat services on the Site; and (b) to assist Trade with the customer service functionality associated with the Chat services. Please see our Privacy Provisions for Covered Users below for details regarding our use and sharing of personal information.

INFORMATION USE AND DISCLOSURE

Please see our Provisions for Covered Users below for additional details regarding the categories of personal information collected.

We use information that we collect about you, including Sensitive Personal Information where applicable, for our internal purposes, including:

  • to establish your Customer account with our Service;
  • to communicate with you about our Service, including sending you marketing messages about Trade and/or third party products and/or services that we think may be of interest to you; to support and enhance your use of the Service and provide you with customer support;
  • to process your order payments, and deliver the products and services that you have requested;
  • to conduct research and analysis about your use of, or interest in, our products, services or content;
  • to serve you content and advertising tailored to your interests on the Site and/or associated with the Service;
  • to enforce our Terms and otherwise manage our business; and
  • to perform functions as otherwise described to you at the time of collection.

By submitting your personal information by and through the Site and/or Service, you agree that we may share, sell, rent, lease or otherwise provide that personal information (but not Sensitive Personal Information) to any third party for any purpose permitted by law, and we may work with other businesses to bring selected retail opportunities to our users. These businesses and third parties may include, but are not limited to, our retail partners. In addition, we may share information that you provide to us, as well as information that we collect from third parties, to serve you ads tailored to your interests on the Site and on other websites or third party services.

By submitting your personal information by and through the Site and/or Service, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”), and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from Trade, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide consent under the TCPA in order to obtain access to the Service, and your consent simply allows Trade to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (i) have your telephone number reassigned to another person or entity; (ii) give up your telephone number so that it is no longer used by you; (iii) port your telephone number to a landline or vice versa; or (iv) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Trade of the Phone Number Change via e-mail at: support@tradecoffeeco.com, or by using one of the methods set forth in the “Contact Us” section below.

We may share your personal information with our authorized service providers (“Service Providers”) to provide a number of administrative services related to the operation of our Service, including fulfilling orders, processing payments, delivering packages, providing customer service and marketing assistance, performing business and sales analysis, supporting our Site functionality and supporting features offered through the Site. Any third party to whom we may disclose personal information, including our Service Providers, may have servers located inside or outside the United States. The Service Providers with whom we share your personal information have agreed to use such information solely to provide the subject services; provided, however, that we cannot guarantee the privacy practices of our third-party Service Providers.

From time to time, we may share your personally identifiable information with our strategic and business partners, including our bank, insurance and audit firms, as well as marketing and business development partners. We may share personally identifiable or other information with our affiliates and third party business partners and across our websites, applications, social media pages and other online platforms. We may transfer personally identifiable information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control (including where we share your personal information, including Sensitive Personal Information, in connection with the due diligence process associated with a potential mergers, sales and similar transactions). Our third party business partners may use your personally identifiable information for their own marketing purposes.

We may disclose such information in response to requests from law enforcement officials conducting investigations, subpoenas or court orders, or if we believe we are otherwise required to disclose such information by law. We also may release personal information where we believe disclosure is necessary to protect our legal rights, enforce our Terms or other agreements or to protect ourselves or others. You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be required by applicable law, including sharing your e-mail address with third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time, and other e-mail marketing laws. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third-parties without permission.

Any third party to whom we may disclose personal information may have servers located inside or outside the United States.

We may use aggregated non-personal information for internal business purposes, such as improving the Site. In addition, we may share aggregated non-personal information (such as the number of daily visitors to the Site) with any of the above parties. We may also share aggregated information that contains no personally identifiable information with any other third party for any other purpose, including for marketing purposes and for conducting general business analysis.

While we use contractual and other measures to ensure protection of personal information, the laws and regulations relating to privacy and personal information protection in other jurisdictions may not be the same as, or similar to, your local privacy laws. The governments, courts, law enforcement or regulatory agencies in these other jurisdictions may be able to request disclosure of personal information through the laws of these countries.

Some third parties’ embedded content or plugins on the Service, such as Facebook “Like” buttons, may allow their operators to learn that you have visited our website, and they may combine this information with other, identifiable information they have collected about your visits to other websites or online services.

SOCIAL MEDIA WEBSITES AND WIDGETS

If you engage in any interaction with Trade, other users or any third-party on any social media websites such as Social Media Websites (“Social Media Websites”), you should be aware that: (a) the personal information that you submit by and through such Social Media Websites can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where Trade responds to any interaction on such Social Media Websites, your account name/handle may be viewable by any and all members/users of Trade’s social media accounts. We are not responsible for the personal information that you choose to submit on any Social Media Websites.

In addition, the Service contains Social Media Website widgets and buttons (“Widgets”), such as the Facebook® and Twitter® share buttons. These Widgets may collect your IP address, as well as which page you are visiting on our Site, and may set a cookie on your browser to enable the Widget to function properly. The Widgets are owned and operated by the applicable Social Media Websites. The Social Media Websites operate independently from Trade, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices.

Your interactions with the Social Media Pages and Widgets are governed by the privacy policies of the applicable Social Media Websites. We encourage you to review the privacy policies and settings of the Social Media Pages and/or Widgets with which you interact to help you understand those Social Media Websites’ respective privacy practices. If you have questions about the security and privacy settings of any Social Media Pages and/or Widgets that you use, please refer to the applicable Social Media Website’s privacy notices or policies.

THIRD-PARTY WEBSITES

The Site and/or Service may contain links to third-party owned and/or operated websites including, without limitation, Social Media Websites, as well as the websites of other third parties. Trade is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Trade has no responsibility or liability relating to them.

DATA SECURITY

We are committed to protecting the security of your information and take reasonable precautions to protect it. We use industry standard encryption technology to protect your data in transit and while it is stored on our servers. This is commonly referred to as transport layer security (TLS) or secure socket layer (SSL) technology. However, internet data transmissions cannot be guaranteed to be 100% secure, and we cannot ensure the security of information during its transmission between you and us. Accordingly, you acknowledge that when you transport such information, you do so at your own risk.

Some of the important safeguards we deploy are digital encryption, digital and physical access controls deployed and managed by our third-party data centers and administrators, and information access authorization controls. Again, data centers and our third-party service providers are not guaranteed to be 100% secure, and so you acknowledge that your information stored in such data centers or service providers is at your own risk.

If we learn of a system breach, we may attempt to notify you and provide information on protective steps, if available, using the Customer Information that you have provided to us or by posting a notice on the Site, via the Service and via other applicable communication platforms. Depending on where you live, you may have a legal right to receive such notices in writing.

RETAINING INFORMATION

We retain Customer 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 Customer 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 Customer 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.

Opt-Out / Unsubscribe

Please see our Provisions for Covered Users below for additional details regarding the categories of personal information collected.

To opt-out of receiving e-mail and other forms of communication from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: support@tradecoffeeco.com.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for the Service, as well as to respond to any inquiry or request made by you. To opt-out of receiving Service-related and/or inquiry response-related messages from Trade, you must cease requesting and/or utilizing the Service and/or cease submitting inquiries to Trade, as applicable.

Accessing, Updating and Deleting Your Personal Information and Related Preferences

Please see our Provisions for Covered Users below for additional details regarding the categories of personal information collected.

Account Information

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have otherwise collected. You may do so by e-mailing us at: support@drinktrade.com. In addition, if you have an online account with us, you may have the ability to review and update your personal information online by logging into your account. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information may terminate your access to certain features of the Service. If you wish to continue using the full complement of Service features, you may not be able to delete all of the personal information that we have on file for you.

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Marketing Communications

You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in any marketing email. You may choose to opt out of receiving marketing communications by Texts in the manner described in our Terms of Service. It may take up to three (3) business days for us to process an opt-out request. However, please note that we may send you what we consider to be important Service-related messages, customer service responses or other communications relating to inappropriate use of the Service or requests from third-parties to access information in your account, without offering you the opportunity to opt out of receiving them.

Location Data

You can choose not to share your location data by adjusting the applicable settings on your mobile device (the manufacturer or your service provider should be able to provide assistance).

Cookies and Other Technologies

As noted above, we use cookies, web beacons and similar technologies for certain purposes such as improving your experience using our Service. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the features offered on the Site and your experience with the Service may be degraded. Please also note that if you have multiple computers or change computers, or use multiple browsers, you will need to disable cookies for each such computer or browser.

Limiting Sharing

We will use reasonable efforts to honor any request that we not share your personal information with third parties for direct marketing purposes. You may make such a request by updating your information at www.drinktrade.com or by sending a written request to the address below:

By U.S. Mail:

Trade Coffee Co
85 Broad St., Suite 09-012
New York, NY 10004
Attn: Privacy Concerns

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@tradecoffeeco.com or write to us at:

Trade Coffee Co. 85 Broad St., Suite 09-012 New York, NY 10004 Attn: Privacy Concerns

We will honor any statutory right you might have to access, modify or erase your personal information. Where you have a legal right to request access or request the modification or erasure of information, we can still withhold that access or decline to correct information in some cases in accordance with applicable law, but will give you reasons if we do so.

Children's Privacy

We do not knowingly or intentionally collect personal information from children under eighteen (18) years of age. If you are not eighteen (18) years of age or older, you are not authorized to use the Service. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors.

Access to the Service from outside of the United States

If you are visiting our website from outside the United States, please be aware that Trade is the data controller for the Service, and we may store and process your personal information on computers in the US and elsewhere in the world where our data centers are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Service, you consent to your information being collected, used and disclosed as described in this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

By mail:

Trade Coffee Co. 85 Broad St., Suite 09-012 New York, NY 10004 Attn: Privacy Concerns

By email: support@tradecoffeeco.com

PRIVACY NOTICE FOR COVERED USERS RIGHTS

This Privacy Notice for Covered Users (“Privacy Notice”) supplements the information contained in the “Privacy Policy. These Privacy Provisions apply solely to the Covered Users, who are residents of the States of California, Colorado, Connecticut, Virginia and Utah, as well as businesses organized under the laws of the State of California. We adopt these Provisions in compliance with the CCPA, CPRA, CPA, CDPA, VCDPA and UCPA (collectively, “Applicable State Laws”). Any terms defined in Applicable State Laws have the same meaning when used in these Privacy Provisions.

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 Covered User or device (“personal information”). In particular, we have collected the following categories of personal information from Covered Users within the last twelve (12) months:

Category Example(s) 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. 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
B. Personal information categories listed in Applicable State Laws. 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 Applicable State Laws. 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 Covered 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. YES
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 Covered User information.
  • Information excluded from the scope of Applicable State Laws, 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 Covered Users. For example, from online registration forms that our Covered Users submit to us in connection with the products and/or services that we offer by and through the Site and/or Service and/or provided through the course of employment and/or through job application. (Categories A, B, C, D, I and L)
  • Indirectly from our Covered Users. For example, through information we collect from our Covered 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 Covered 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 Covered Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from Covered 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 serve you Targeted Advertising (as defined below). (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, I and L)
  • To carry out operations associated with, or your employment and/or job application submitted to, us. (Categories A, B, D, I 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, F 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, I 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, I and L)
  • As described to you when collecting your personal information or as otherwise set forth in Applicable Privacy Laws. (Categories A, B, C, D, F, I 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, I 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.

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 Covered Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of Covered 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 Covered 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 Applicable State Laws.
  • Category C Protected classification characteristics under Personal information categories listed in Applicable State Laws.
  • Category D Commercial information.
  • Category F Internet or other similar network activity.
  • Category I Professional or employment-related information (but only for facilitating the relationship with Covered User job applicants and employees)
  • 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, I 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, F and L)
  • 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, I 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 Applicable State Laws.
  • Category C Protected classification characteristics under Applicable State Laws.
  • 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

Applicable State Laws provide Covered Users (residents of California, Colorado, Connecticut, Utah and Virginia) with specific rights regarding their personal information. The provisions below describe your rights under Applicable State Laws, and explain 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 Covered User request to us by either:

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:

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 established by Applicable State Laws), Category C (Protected classification characteristics under Applicable State Laws), Category D (Commercial information), Category I (Professional or employment-related 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 established by Applicable State Laws), Category C (Protected classification characteristics under Applicable State Laws), Category D (Commercial information), Category I (Professional or employment-related 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:

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).

Right to Know, 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 Covered 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.

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.

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 Covered 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 Covered 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 Covered 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.

Exercising Access/Right to Know, Data Portability, Right to Correct and Deletion Rights

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

The verifiable Covered User access/right to know, data portability, right to correct and/or deletion rights 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 Covered User request does not require that you create an account with us. We will only use personal information provided in a verifiable Covered User request to verify the requestor's identity or authority to make the request.

Response Timing and Format; Appealing a Denial

We endeavor to respond to all verifiable Covered User access/right to know, 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 Covered 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.

If we deny any Covered User access/right to know, data portability, right to correct and/or deletion rights request, you may submit an appeal of our decision within thirty (30) days of your receipt of our notice of denial by e-mailing 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.

Right to Opt-Out of Profiling

You have the right to opt-out from any Profiling that may be conducted by Trade. For purposes of these Provisions, "Profiling" means any form of automated processing performed on your personal data to evaluate, analyze or predict personal aspects related to you or your economic situation, health, personal preferences, interests, reliability, behavior, location or movements. You have the right to opt-out of our Profiling you. To exercise your right to opt-out of our Profiling you, please submit a verifiable Covered User request to us by either:

We endeavor to act on all Profiling opt-out requests as soon as practicable, but in all cases within forty-five (45) days of the receipt of your request.

Right to Opt-Out of Targeted Advertising

You have the right to opt-out from Targeted Advertising conducted by Trade. For purposes of these Provisions, "Targeted Advertising” means displaying advertisements to you where the advertisements are selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests. You have the right to opt-out from Targeted Advertising. To exercise your right to opt-out of our Targeted Advertising, please submit a verifiable Covered User request to us by either:

We endeavor to act on all Targeted Advertising opt-out requests as soon as practicable, but in all cases within forty-five (45) days of the receipt of your request.

Authorized Agents

Covered Users may permit an Authorized Agent to exercise any rights granted under Applicable State Laws as set forth above. 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 delete, 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.

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

Non-Discrimination

We will not discriminate against you for exercising any of your rights under Applicable State Laws. Unless permitted by Applicable State Laws, 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;
  • Retaliate against any employee, job applicant or independent contractor; 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 these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, 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 these Privacy Provisions, 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 Applicable State Laws, please do not hesitate to contact us by either: