Privacy Policy

1 Definitions

2 Information We Collect, Categories of Sources, and Purposes

Set forth below are the categories of Personal Information we affirmatively collect and that have been collected in the preceding 12 months, the categories of sources from which the Personal Information was collected, and the business or commercial purpose for such collection. We may not collect all information referenced below, nor use all Personal Information for all purposes listed.

3 Cookies & Tracking Technologies

A cookie is a small file of letters and numbers stored on your browser or computer hard drive. Cookies contain information transferred to your computer. We use cookies and similar technologies - such as web beacons and tracking pixels - to analyze trends, administer our website, personalize content and ads, track user movements, provide relevant browsing experiences, and gather demographic information about our user base.

You can control cookies at the individual browser level, but disabling cookies may limit certain features or functions of our website. Browser-level controls apply only to the browser and device you are using and are not a substitute for the choices described in the "Your Privacy Choices" section below.

Types of Cookies We Use

If you want to remove existing cookies, use your browser options. To block future cookies, change your browser settings accordingly. Please note that deleting and blocking cookies may impact your user experience, as some site features may not function properly.

We also use web beacons, pixels, and tracking pixels (transparent 1x1 graphic images or JavaScript tags) placed on web pages and some forms of email to collect information about your use of the site and to trigger ads on participating websites.

Cookie Consent and Preferences

Where required by applicable law, we obtain your consent before placing cookies or similar technologies that are not strictly necessary for the operation of our website. You may accept, reject, or change your cookie preferences at any time using the "Cookie Preferences" link in the footer of our website. Your acceptance of our general terms of use, and your continued use of our website, do not by themselves constitute consent for this purpose.

Do Not Track and Opt-Out Preference Signals

Some browsers offer a "Do Not Track" ("DNT") setting. Because no common industry standard for responding to DNT signals has been adopted, our website does not currently respond to DNT signals. We do treat the Global Privacy Control ("GPC") and comparable opt-out preference signals as valid opt-out requests for the browser or device on which the signal is enabled, as described in the "Your Privacy Choices" section below.

4 Third-Party Advertising & Analytics Platforms

We work with a number of third-party advertising, analytics, and social media platforms that may collect or receive information about your interactions with our website and ads. These platforms place their own cookies or pixels on your browser and use that data to serve you relevant advertising on our website and across the internet.

5 Personal Information We Disclose and Share for Targeted Advertising

Disclosure to Service Providers

We disclose and have disclosed in the preceding 12 months Personal Information to our service providers and contractors for the following business purposes:

• Auditing of Ad Impressions: For counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
• Short-Term / Transient Use: Including non-personalized advertising shown as part of a consumer's current interaction, where data is not used to build a profile beyond the current interaction.
• Services on Our Behalf: Maintaining or servicing accounts, customer service, processing orders/transactions, verifying customer information, processing payments, providing financing, analytic services, storage, and similar services.
• Advertising and Marketing Services: To provide advertising or marketing services on our behalf.
• We do not sell your Personal Information. However, our disclosure of certain Personal Information with third-party advertising and analytics partners for cross-context behavioral advertising (targeted advertising), may be considered a "sale" or "share" under California and certain other state laws. You may exercise applicable opt-out rights as described below.

As Necessary: We may also disclose Personal Information as necessary:

• to comply with any legal process;
• to respond to requests from public and government authorities;
• to enforce our terms and conditions;
• to protect our operations, rights, privacy, safety or property; and
• to allow us to pursue available remedies or limit damages.

We may also use Personal Information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer, or other disposition of our business, assets, or stock.

We have not sold Personal Information for monetary consideration in the preceding 12 months. The following categories of Personal Information have been disclosed to third-party advertising and analytics partners for cross-context behavioral advertising (targeted advertising), which may be considered a "sale" or "share" under certain state laws:

6 Your Privacy Choices: How to Opt Out of Targeted Advertising

You may opt out of our disclosure of Personal Information for targeted advertising (which may be considered a "sale" or "share" under certain state laws) at any time and free of charge, by any of the following methods:

• Selecting the Your Privacy Choices link that appears in the footer of every page of our website, which will generate an email addressed to Michelli for submission of your request;
• Enabling the Global Privacy Control ("GPC") or a comparable opt-out preference signal in your browser or through a browser extension. We treat that signal as a valid opt-out request for the browser or device on which it is enabled, so you will need to enable it on each browser and device you use; or
• Contacting us by telephone at (800) 903-8823 or by email at privacy@michelli.com.

We will not require you to create an account, and we will not require you to verify your identity, in order to act on an opt-out request. You may also designate an authorized agent to submit an opt-out request on your behalf. We will act on an opt-out request as soon as feasibly possible and in no event later than fifteen (15) business days after receipt.

7 Automated Decision-Making and Artificial Intelligence

We do not use automated decision-making technology, including artificial intelligence tools, to process Personal Information in ways that produce legal or similarly significant effects for you.

Where required by Colorado, Connecticut, Texas, Louisiana, or other applicable law, we will, as applicable:

• provide notice before using automated decision-making technology that produces a legal or similarly significant effect;
• provide an opportunity to opt out of, or in some cases appeal, a decision made solely through automated processing; and
• conduct a data protection assessment where required by applicable law.

We do not knowingly use automated decision-making technology to make decisions based on a consumer's race, religion, health, sexual orientation, immigration status, or other legally protected characteristic in a manner prohibited by applicable law.

If you have questions about our use of automated decision-making technology or would like to exercise a right described in this section, you may contact us using the information in the "How to Contact Us" section below.

8 Our Retention Policy

To determine the appropriate retention of information, we consider: the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process the information; whether we can achieve those purposes through other means; applicable legal requirements; and applicable privacy rights requests. When Personal Information is no longer needed for the purposes described in this Privacy Policy, to fulfill statutory recordkeeping requirements, or to comply with an applicable deletion request, we securely delete, destroy, or deidentify it, unless a legal exception permits or requires retention.

If you are not selected for a position, we may retain your résumé and application materials to consider you for future job openings at Michelli. You may request that we delete your résumé and application materials at any time by contacting us using the information in the "How to Contact Us" section below.

9 Data Security and Information Security

Michelli maintains an information security program to help manage safeguards designed to protect the confidentiality, integrity, and availability of company, customer, and business information. The program provides a framework for identifying and addressing information security risks across Michelli's operations on an ongoing basis. We implement technical, organizational, administrative, and physical measures to help ensure a level of security appropriate to the risk to the Personal Information we collect, use, process, and disclose. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to help ensure the security of processing. Where required by applicable law, we will conduct a documented assessment process for higher-risk processing activities, such as targeted advertising or profiling that produces a legal or similarly significant effect.

10 Children

We do not direct our websites or applications to children under thirteen (13) years of age. We do not knowingly collect information from persons under 13 years of age or provide any Personal Information from such persons to any third party for any reason whatsoever. We do not knowingly allow persons known to be under 13 years of age to receive direct marketing communications from us. No information should be submitted to our websites or applications by persons under 13 years of age. When appropriate, we may ask you to indicate your date of birth to verify compliance with the age requirements set forth herein. Additional protections that apply to minors between the ages of 13 and 17 are described in the "Consumer Rights" section below.

11 Video Content

Our website may embed or link to video content, such as videos hosted on third-party platforms. We do not rent, sell, or deliver audio-visual materials. Any information collected in connection with embedded video is handled as described in the Cookies & Tracking Technologies and Third-Party Advertising & Analytics Platforms sections above.

12 Consumer Rights

Your Rights if You Are a Resident of California

California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2023 (CPRA), and related regulations. These rights are subject to certain exceptions and verification mechanisms.

• Right to Know: You have the right to know the categories of Personal Information we have collected about you, categories of sources, business or commercial purposes for collection, categories of third parties to whom we disclose it, and specific pieces of Personal Information collected about you. Under California Civil Code Section 1798.83 (the "Shine the Light" law), we do not disclose Personal Information to third parties for those third parties' own direct marketing purposes.
• Right to Know What Was Disclosed or Sold: You have the right to request categories of Personal Information sold or shared and the categories of third parties involved, by category of Personal Information.
• Right to Deletion: You have the right to request deletion of your Personal Information, subject to exceptions. We will inform you of any Personal Information we cannot delete and the reason.
• Right to Correct Inaccurate Information: If you believe Personal Information we maintain about you is inaccurate, you have the right to request correction. We will use commercially reasonable efforts to correct the information as directed.
• Right to Opt-Out of Sale and Sharing: You may opt-out of the sale or sharing of your Personal Information for cross-context behavioral advertising. See "Your Privacy Choices" above for the methods available to you, including the "Your Privacy Choices" link in our website footer and the Global Privacy Control (GPC) opt-out preference signal. We do not require you to verify your identity in order to submit an opt-out request.
• Right to Limit Use of Sensitive Personal Information: Because we do not affirmatively request Sensitive Personal Information through our website or Careers form, this right does not apply to our current website practices. If our practices change, we will update this Privacy Policy and describe how you may submit a request to limit our use of Sensitive Personal Information.
• Right to Non-Discrimination: If you choose to exercise any of your rights, you have the right not to receive discriminatory treatment by us.

Your Rights if You Are a Resident of Another State

Depending on your state of residency, you may have certain rights related to your Personal Information. Louisiana residents have the rights described in this section and under the Louisiana Data Privacy Act, and may appeal a declined request as described below. Nevada residents also should refer to the "Nevada Privacy Notice" section below. You may submit a request by calling us at (800) 903-8823 or emailing us at privacy@michelli.com. Please note that not all of these rights may be applicable to you, they are subject to certain exceptions, and certain rights are subject to verification mechanisms. The privacy laws of states other than California apply only to individuals acting in a personal or household capacity. They do not apply to information we process about individuals acting in a commercial or employment context, including the personnel of our business customers and applicants for employment. California residents should refer to the section above.

• Right to Know: Whether we are processing your Personal Information. Oregon residents also have the right to know categories processed and specific third parties to which we have disclosed it.
• Right of Access: Access to your Personal Information and a copy in a readily usable format, if feasible.
• Right to Correct Inaccuracies: Request correction of inaccuracies in your Personal Information.
• Right to Delete: Request deletion of your Personal Information, except where retention is required by law or contractual obligation.
• Right to Data Portability: Obtain a copy of your Personal Information in a portable and, if feasible, readily usable format.
• Right to Opt-Out: Prevent your Personal Information from being used in targeted advertising, sold, or used for automated decision-making or profiling that may produce legal or similarly significant effects.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your rights.
• Right to Consent Before Processing Sensitive Data: We do not currently affirmatively request sensitive data through our website or Careers form and therefore do not process such data for residents of Louisiana without consent. If our practices change, we will obtain affirmative opt-in consent where required before processing sensitive data.
• Furthermore, if we obtain actual knowledge that you are at least 13 years of age and under 18, we will not, without your consent (or, where required by law, a parent or guardian's consent) process your Personal Information for targeted advertising, profile you for decisions with legal or significant effects, or sell your Personal Information, or share it for cross-context behavioral advertising.

Verification of Consumer Requests

Requests to opt out of targeted advertising, or of the sale or sharing of Personal Information, are not subject to verification. See "Your Privacy Choices" above for the methods available to you.

For all other requests, you may submit a request via phone at (800) 903-8823 or email at privacy@michelli.com. To help protect your privacy and maintain security, we will take steps to verify your identity. Our verification procedure may differ depending on the type of request and the sensitivity of the Personal Information involved. We will verify your identity using information we already maintain about you, and the degree of certainty we require will be proportionate to the sensitivity of the Personal Information involved and the risk of harm from unauthorized disclosure. If we cannot verify your identity using commercially reasonable efforts, we may request additional information from you, which we will use only for verification and will then delete. If you use an authorized agent, we may require proof of the agent's authority and may contact you directly to confirm the request.

There may be situations where we cannot grant your request - for example, if you ask us to delete Personal Information we are obligated to keep under applicable law, if our use serves a legitimate purpose such as security, or if the request compromises the privacy of others, is overly repetitive, or extremely burdensome.

We will respond to valid requests no later than 45 calendar days. If necessary, we may take up to an additional 45 days but will provide notice and an explanation. Valid requests under "Right of Access" and "Right to Data Portability" will be transmitted securely. If we cannot fulfill your request, we will notify you of the decision and reasons within 45 days, at which point you may have the right to submit an appeal or seek assistance from your state attorney general.

Appeals

If we decline to act on your request, we will notify you of our decision and the reasons for it, and we will provide instructions for appealing. You may submit an appeal by replying to our response or by contacting us using the telephone number or email address above. We will respond to your appeal in writing, with a written explanation of the reasons for our decision, within sixty (60) days of receipt. If we deny your appeal, we will provide you with a method for contacting the attorney general of your state to submit a complaint. Louisiana residents may submit a complaint to the Louisiana Attorney General.

13 Nevada Privacy Notice

Nevada law provides that Nevada residents may opt-out of the "sale" of "covered information" to third parties, including but not limited to name, address, social security number, and online service activity. We do not sell your covered information as defined under Nevada law, which is generally limited to licensing covered information for a third party to further license or sell. Even so, if you are a Nevada resident, you may submit a verified opt-out request by calling us at (800) 903-8823 or emailing us at privacy@michelli.com.

14 How to Contact Us

If you have any questions or concerns about our privacy policies and practices, please feel free to contact us: