Instinct Pet Food and its parent company M.I. Industries, Incorporated (“we” or “us”) respect the privacy of every person who visits our websites or provides information to us. This page details our specific practices and policies regarding the collection and use of your personal information. Use of our websites or services indicates your acceptance of this Privacy Policy.Collection and Use of Information

Through our website, https://www.instinctpetfood.com/ (the “Website”), we collect several types of information from and about users of the Website, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, or telephone number;
• that is about you but individually does not identify you, such as job history, skills, and/or general resume information; and
• about your internet connection, the equipment you use to access our Website, and usage details.

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For example, we collect and store the name of the domain and host from which you access the Internet (for example, aol.com or princeton.edu); the Internet protocol (IP) address used to access our Website; the browser software you use and your operating system; the date and time you access our Website; and the Internet address of the website from which you linked directly to our Website. We use this information to measure the number of visitors to the different sections of our Website, and to help us make our Website more useful.

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We may collect such information automatically using cookies to help us design and optimize web content for you. A cookie is a message given to a web browser by a web server. The browser stores the message in a text file. The message is then sent back to the server each time the browser requests a page from the server. Cookies are used to store data about a user while browsing and using our Website. We use cookies to improve our products and your experience on our Website by evaluating the use of our Website, products and services, to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about your use of our website with our social media, advertising and analytics service providers. By agreeing to the use of cookies on our website, you direct us to disclose your personal information to these service providers for those purposes.

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It is always possible for you to visit our Website without disclosing your personal information. This requires that you have disabled cookies. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

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We may also collect personal information directly or indirectly from you when you use our Website or other services or buy our products. We may use or disclose the personal information we collect for one or more of the following purposes:

• Presenting our Website and its contents to you.
• Processing and following up on your requests, orders, transactions, and preventing transactional fraud.
• Communicating with you, including providing you with support and responding to your inquiries, comments, or requests for information, as well as investigating and addressing your concerns.
• Reviewing and responding to your job applications and making hiring decisions.
• Notifying you about promotions and other information regarding our products. For example, we may send you educational information, promotional offers, or other information regarding our retailer education portal, including via email.
• Personalizing your experience on our Website and delivering advertisements, content, and product and service offerings relevant to your interests, including based on your Pet Profile, to make your online experience smooth and meaningful.
• Fulfilling the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. Similarly, if you share your name, email address, and zip code as part of a Pet Profile, we will use that personal information to set up your Pet Profile. Also, if you share your information to enter a contest sponsored by us, we will use such information in connection with running the contest.
• To provide, support, personalize, and develop our Website, products, and services.
• Helping maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• Testing, research, analysis, and product development, including developing and improving our Website, products, and services.
• Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in applicable law, including the CCPA (as described below in the Privacy Notice to California Residents).
• Evaluating or conducting 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 about our consumers is among the assets transferred.
• For any other purpose with your consent.

When we ask for your personal information, our primary goal in collecting such information is to give you a meaningful experience on our Website and to allow us to better develop new products and services which are relevant to consumers like you.

Your personal information will be used solely by us and our contracted vendors; it will not be sold to or provided to any third party. We may also enhance or merge personal information that we collect with data obtained from third parties.

If you are a resident of California, you are entitled to certain rights as per the California Consumer Privacy Act of 2018 (CCPA). For more information, see the Privacy Notice to California Residents section below.

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Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

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Links to Other Websites

Our Website may contain links to other websites that are not operated by us, including websites of our subsidiaries and affiliates that are not operated by us. If you click a link to another website, you will be directed to that website. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services, including websites of our subsidiaries and affiliates that are not operated by us.

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Children Under the Age of 16

The Website is not intended for children under 16 years of age. No one under age 16 should provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16 please contact us at https://feedback.naturesvariety.com/clientform.php.

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Communication Choices

You may opt in to receive emails, newsletters or other communications from us. If you wish to discontinue receiving this information, you may update your preferences by using the “Unsubscribe” link found in the emails that we send to you or by contacting us at https://feedback.naturesvariety.com/clientform.php.

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Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained this Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (as used in this section, “consumers” or “you”). We adopt this notice to comply with the CCPA and any terms defined in the CCPA have the same meaning when used in this notice.

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Information We Collect

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

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Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:

• 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; or
• 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.

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We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• From our affiliates and subsidiaries.
• From third-party business partners such as social media sites, ad networks, and analytics providers.

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Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the business purposes or uses listed above in the Collection and Use of Information section. In addition, we may use or disclose such Personal Information as described to you when collecting your Personal Information or as otherwise set forth in the CCPA. We will not collect additional categories of Personal Information or use the Personal Information we collected for additional purposes without providing you notice.

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Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

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Disclosures of Personal Information for a Business Purpose

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

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category I: Professional or employment-related information.
• Category J: Non-public education information.
• Category K: Inferences drawn from other personal information.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• service providers, including email service providers, consumer relations service providers, customer support service providers, communications service providers, employee recruitment and application processing service providers, our marketing service providers, and the provider of our retailer education portal;
• our affiliates and subsidiaries; and
• legal representation and other advisors, including with regard to prevention harm to our company, our products or services, or a person or property (e.g., fraud prevention).

No Personal Information Sales

We do not sell any Personal Information that we collect or use.

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Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

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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 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we 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. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

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

1. Complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at [888-519-7387].
• [Visiting [WEBSITE ADDRESS].]
• [Emailing [cservice@instinctpetfood.com].¹

Only you, or a natural person or entity registered with the California Secretary of State that you authorize in writing, or otherwise properly authorize, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

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

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• 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 the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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Response Timing and Format

¹Note to Draft: Under the CCPA, you will need at least a toll-free number and an online method (such as a designated email address) for consumers to submit requests. One of the methods should reflect how you primarily interact with consumers. We used the toll-free number and email on the “Contact Us” portion of the website, however, you can designate a specific toll-free number and email if you would like.

We will confirm receipt of your request within ten (10) business days of receipt. We endeavor to respond to a verifiable consumer request within 45 calendar days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons 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 consumer 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.

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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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value to us of your Personal Information and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

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Contact Information

If you have any questions or comments about this Notice, 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 at:

• Phone: 888-519-7387
• Website: https://feedback.naturesvariety.com/clientform.php
• Email: cservice@instinctpetfood.com
• Postal Address:
  Instinct Pet Food
  Attn: [CONTACT NAME/DEPARTMENT]
  55 West Port Plaza Drive
  Suite 200
  St. Louis, MO 63146

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Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [cservice@instinctpetfood.com] or write us at: Instinct Pet Food, 55 West Port Plaza Drive, Suite 200, St. Louis, MO 63146.

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“Do Not Track” Signals

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. At this time, our website does not support DNT codes. However, except in the case of analytics cookies and as described herein, our Website limits tracking to the uses described above and our Website does not track your use across multiple websites, however, other websites to which we link may track you. Please review their privacy policies to understand how you may be tracked.

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Changes to our Privacy Policy

We reserve the right to modify our Privacy Policy in the future as we deem necessary at any time. Any such modification will result in this Privacy Policy being modified to reflect this change on or before the date the change takes effect. Please refer to the online version of this Privacy Policy for the latest information regarding our privacy policy and practices. Your continued use of our Website following the posting of any modifications constitutes your acceptance of such modifications.

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Limitations of Medical Information

The material available on all our Website is, without limitation, provided for informational and educational purposes only; it is not intended to take the place of advice from a licensed, practicing veterinarian. Only a practicing veterinarian who examines your pet can give effective veterinary advice or diagnose your pet’s medical problems. Your reliance on the information you get on any website is solely at your own risk. If your pet has a specific health problem, please contact your veterinarian immediately.

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Governing Law

Our Website is intended for use by residents of the United States only. All matters relating to the Website and this Privacy Policy are governed by applicable U.S. federal and state laws. Please be advised that any information you provide us will be transferred to the United States and by submitting such information you explicitly authorize such transfer.

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Your Consent to this Privacy Policy

By using the Website, you signify your assent to the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use the Website or submit any personal information to us.
Contact Information

If you have any questions or comments about this Privacy Policy or the ways in which we collect and use your information, please do not hesitate to contact us at: https://feedback.naturesvariety.com/clientform.php or Instinct Pet Food, 55 West Port Plaza Drive, Suite 200, St. Louis, MO 63146.