Privacy Policy

Contents

1. What this Privacy Policy Covers.
2. Personal Information We Collect.
3. How We Use Personal Information.
4. When and Why We Share Personal Information and Who We Share It With.
5. How You Can Opt Out of Promotional Emails.
6. How You Can Restrict Internet Tracking Technologies and Personalized Advertising.
7. Social Media Activities and Links to Other Websites.
8. Protection of Personal Information.
9. International Users.
10. Changes to this Privacy Policy.
11. How to Access and Manage Your Personal Information.
12. How to Contact Us.
13. Notices and Rights for California Residents.

1. What this Privacy Policy Covers.

Sovos Brands Intermediate, Inc., a Delaware corporation, together with its subsidiaries (“Sovos Brands,” “we,” “our” or “us”), owns and markets the Rao’s Homemade, Michael Angelo’s and noosa brands, as well as other brands. This Privacy Policy explains how we collect, use, and share personal information when individuals use our websites or other online services, and when they communicate with us by email, social media, telephone or some other means. It also covers personal information that we may obtain from business partners and other sources. If you use our services or websites or communicate with us in some other way, you are agreeing that you have read and understood this Privacy Policy and consenting to the collection, use and sharing of your personal information as described in it.

In this Privacy Policy we refer to you and other people who use our services or websites, or who communicate with us in some other way, as “you,” “individuals,” “users,” or “consumers.”

The term “personal information” has a specific meaning in this Privacy Policy. It refers to:

• Directly Identifying Information. Non-public information that identifies an individual directly, such as his or her name, street or e‑mail addresses, social security number, birthday, and phone number;
• Information Identifiable to an Individual. Information that identifiably belongs to a particular individual, even though it may not be a direct identifier, such as his or her computer’s internet protocol (“IP”) address, mobile device hardware ID information and geolocation data, and cookies and other internet tracking data used in web browsers and other software; and
• Information about Individuals. Other information that can reasonably be associated with or identified to an individual, such as his or her interests, job, personal characteristics, and preferences.

This Privacy Policy only relates to personal information, so nothing about this Privacy Policy in any way restricts our ability or right to collect, use, share, or disseminate information that can’t reasonably be linked to you or used to identify you. That includes data we may derive from personal information that has been anonymized or modified some other way so that it can’t reasonably be linked to you or used to identify you.

2. Personal Information We Collect.

Summary of the Categories and Types of Personal Information We Collect.

The chart below summarizes the categories and types of personal information we have collected about users in the last 12 months. Not all of the information listed below has necessarily been collected for every individual: what types and amounts of information are actually collected about any particular individual in any given 12-month period depends on how that individual uses our websites and services and communicates or interacts with us.

Types of Information Automatically Collected when You Visit Our Websites.

We (and certain vendors we work with) automatically collect and store data about visitors to our websites and other online services using cookies and other online tracking technologies, including:

• Identification: Information about the user’s prior visits to our websites or use of our online services, including any username and password or other credentials used to access the account and any other personalized services.
• Device: The IP address, browser type and operating system, and other information about the device used to access our websites or services.
• Usage: device’s browsing history, search history, and stored information related to the device’s interactions with our websites and certain other websites, applications and ads.
• Location information: The IP address and other location information that may be transmitted by a user’s mobile device. Whether this information is transmitted, how specific it is and how much of it there is depends on what type of device the user is using and how it is configured.

Data collected this way might not identify you on its own, but may be combined with information from other sources to identify your interests and preferences. We may use the information derived from these technologies for data analytics, personalized advertising and other marketing purposes.

In some cases, we use third-party service providers to help us provide and administer our websites and other online services, or to administer and provide them (or certain features of them) to you on our behalf. Those third-party service providers may also collect and use the types of data described above; however, our policy is to place restrictions on what they can do with that information. For more information on what types of third-party service providers we use and what they do with the data we collect, see the sections below titled “When and Why We Share Personal Information and Who We Share It With,” particularly subsections on “Service Providers,” “Payment Processors,” “Data Analytics Services and Cookies” and “Third-Party Ad Services.”

For more information about the technologies described above, including how they function, why we use them, and some steps you can generally take to restrict them, see the sections titled “How We Use Personal Information” and “How You Can Restrict Internet Tracking Technologies and Personalized Advertising.”

How We Collect Personal Information.

As described above, we generally collect personal information directly from you, when (1) you affirmatively communicate it to us, (2) you transact business with us, or (3) it is automatically collected electronically when you use our websites or other electronic services. Outside of that, we may collect personal information about our own users from third-party sources, and may combine it with other information (including information we have collected directly from users) to update, expand and analyze our records, to identify new customers, and to offer or provide products and services that are tailored to individual users’ interests. Those other sources of personal information include:

• Third Parties: Other businesses that we share marketing and prospective customer information with, either because they provide services to us, or they provide services to you on our behalf or work with us to provide services to you;
• Databases: Public and commercial databases, including marketing research and analytics resources that we may get demographic information from (for example, about the age, sex, household income, job industries and job titles of individuals); and
• Social Media: When individuals use social media platforms to send us messages or other content or to interact with us in other ways, those platforms may also transmit personal information about those individuals and their accounts with those platforms. By interacting with us through those platforms, you are giving us permission to collect, store and use the information we receive from them according to this Privacy Policy. (Those platforms’ own terms, conditions and privacy policies also apply to that information.)

3. How We Use Personal Information.

We use personal information to:

• Communicate with our users as necessary or as they request;
• Connect users with our brands, such as Rao’s Homemade, Michael Angelo’s and noosa, as well as certain other products or services we think might be of interest to them;
• Develop content for our websites and other electronic services;
• Perform and manage logistics, operational support, research and development, marketing, business planning, and other business functions for our brands or on their behalf;
• Provide security and prevent fraud, enforce our Terms of Use and other agreements and comply with legal requirements; and
• Conduct any other legitimate business activities.

In this Privacy Policy we refer to you and other people who use our services or websites, or who communicate with us in some other way, as “you,” “individuals,” “users,” or “consumers.”

The term “personal information” has a specific meaning in this Privacy Policy. It refers to:

• Directly Identifying Information. Non-public information that identifies an individual directly, such as his or her name, street or e‑mail addresses, social security number, birthday, and phone number;
• Information Identifiable to an Individual. Information that identifiably belongs to a particular individual, even though it may not be a direct identifier, such as his or her computer’s internet protocol (“IP”) address, mobile device hardware ID information and geolocation data, and cookies and other internet tracking data used in web browsers and other software; and
• Information about Individuals. Other information that can reasonably be associated with or identified to an individual, such as his or her interests, job, personal characteristics, and preferences.

This Privacy Policy only relates to personal information, so nothing about this Privacy Policy in any way restricts our ability or right to collect, use, share, or disseminate information that can’t reasonably be linked to you or used to identify you. That includes data we may derive from personal information that has been anonymized or modified some other way so that it can’t reasonably be linked to you or used to identify you.

4. When and Why We Share Personal Information and Who We Share It With.

We may use and share any of the information we collect, including personal information, in whatever ways we believe are reasonable and consistent with fair business practices and the law. This includes sharing personal information of each of the types described above with the following categories of third parties for the following reasons:

• Affiliated Companies. Affiliated companies are companies that are part of our corporate family through some significant shared ownership interest (i.e., we partly or wholly own them, or they have an ownership interest in us, whether directly or through another company). We may share personal information with them to coordinate business functions between Sovos and them and among them, and facilitate the performance of certain business functions by Sovos for and on behalf of certain affiliates (including the whole group) on a consolidated business, such as: communicating users’ interests, customizing user content, providing users with information and services they request, and conducting research on site visitors for business and product planning and improvements. This includes the sharing of personal information collected by Sovos with noosa yoghurt, Michael Angelo’s and Rao’s Homemade brands, and personal information collected by them with Sovos. For more information on how those specific companies use, collect and share personal information, see their privacy policies located at https://www.noosayoghurt.com/privacy-policy/, https://www.michaelangelos.com/privacy-policy/, and https://www.raos.com/privacy-policy/, respectively.
• Joint Promotions. We may conduct joint promotions together with other companies, which may involve sharing certain personal information with them (and their service providers) as necessary to conduct the promotion. We will not share this information with them for any other purpose without your consent. Promotions may be governed by their own sets of official rules. If you participate in one, you are agreeing to those additional rules, which may require you to provide certain additional information or consents to us, to third parties involved in the promotion, or to the public.
• Service Providers. We employ third parties to perform technology, administrative, marketing, advertising, customer service and other business functions for us, or on our behalf, or on behalf of our affiliates or brands (described in more detail below). These service providers may have access to personal information to perform their functions on behalf of our business, but they are not permitted to use it for their own commercial purposes.
• Payment Processors. Third-party payment processors may process payments for products and services that users request from our affiliates or brands. When you provide information to a payment processor, it is subject to its own terms, conditions and policies, and not ours. We are not responsible in any way for such information.
• Data Analytics Services and Cookies. When you use our websites and online services, third-party data analytics services such as Google Analytics may collect data about you and your activities, including personal information, using cookies, pixels, tracking beacons and similar technologies. These parties may also use the aggregated data they collect on our websites for their own business purposes. We recommend learning about how Google collects and processes such data at https://policies.google.com/technologies/partner-sites, and about your rights related that data and their collection of it, including controls available to manage collection and use of your information, at https://policies.google.com/privacy. For more information on how to manage your data, see the section below titled “How You Can Restrict Tracking Technologies and Personalized Advertising.”
• Third-Party Ad Services. We may use third-party marketing and advertising services to help us identify, and reach, individuals who may be interested in our brands’ products and services. These services also may help us to deliver marketing campaigns through general or personalized digital advertising, direct e-mail messages, postal mailings, and print publications. We may share aggregated information, such as demographics and statistics, with them, and we use commercially reasonable measures to remove information that identifies you individually. These campaigns may involve placement of advertisements on websites, services and apps owned and operated by other companies. When you use those other websites, services and apps, the businesses that own and operate them may set their own cookies or use other web technologies to collect personal information about you. That collection, and their use of that information, is governed by their own privacy policies and terms and conditions, and not ours. For more information, see the sections titled “How You Can Restrict Tracking Technologies and Personalized Advertising” and “How to Opt Out of Promotional Emails” below.
• Legal Process and Security. We may disclose user information to third parties, including personal information, to enforce our Terms of Use, respond to and resolve claims or complaints, prevent fraud, comply with or respond to law enforcement or legal process or a request for cooperation by a government entity, whether or not legally required, and for other risk-management purposes.
• Business Transactions. We reserve the right to disclose or transfer your personal information in connection with a business transaction such as a financing, reorganization, merger, or substantial sale of a business.
• Third-Party Platforms. Our websites may contain links to other websites that are not owned or controlled by us. Please recognize that when you click such a link, you are leaving our website. We are not responsible for the privacy practices of any other sites or services, whether we link to them or not. We encourage you to read the terms, conditions and privacy policies of the other sites and services you use.

We retain your personal information as long as necessary to provide you with services and products you request, comply with our legal obligations, resolve disputes, enforce our agreements and serve other legitimate business purposes. We may also retain and use user information for our legitimate marketing purposes (unless you instruct us to stop sending communications to you: see the section titled “How You Can Opt Out of Promotional Emails” below).

5. How You Can Opt Out of Promotional Emails.

If you subscribe to emails from one of our brands, you can choose to stop receiving such email messages by following the “unsubscribe” instructions located near the bottom of each email. Please note that opt-out requests may take up to 10 days to be effective. Even if you opt out of promotional emails, you may still receive non-promotional communications, such as about your accounts or purchases with our brands.

6. How You Can Restrict Tracking Technologies and Personalized Advertising.

You can control how cookies and other internet and similar technologies track and log data about your internet use and deliver personalized ads to you on our websites and others. These controls include:

• Browser Settings. Managing the settings of your browsers, apps and devices, including preferences for how your content and information are stored;
• Flash Cookies. Managing flash cookies (which are used to display personalized ads) by clicking here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html;
• Third-Party Data Collectors. Communicating directly with third parties that may collect data on websites you visit, such as:
  • Google: https://policies.google.com/privacy;
  • Adobe: https://www.adobe.com/privacy.html;
  • Facebook: https://www.facebook.com/privacy/explanation; and
  • Twitter: https://twitter.com/en/privacy;
• Security Software Purchasing software that can be installed install on your devices to limit third parties’ ability to track your browsing activity;
• Digital Advertising Alliance. Visiting http://optout.aboutads.info to learn more about personalized advertising and how to opt out of it through your browser with companies in the Digital Advertising Alliance;
• Do-Not-Track Requests. Enabling your browser’s Do Not Track (“DNT”) function to automatically request websites not track you. DNT requests are only honored by some advertisers and websites. Our websites do not respond to DNT signals.

If you restrict the use of cookies and other technologies, certain web services may not work properly. If you restrict personalized advertising, you will still receive ads, but they will not be personalized based on your browsing activity.

7. Social Media Activities and Links to Other Websites.

This Privacy Policy does not apply to any information you share or post on, or communicate through, any social media platforms and services (“Third-Party Social Media Services”), such as Twitter or Facebook, whether or not you post comments, questions, or images, or interact or communicate with or about us or our brands. We are not responsible for any personal information you post on or communicate through any Third-Party Social Media Services or how others may use your information or images.

Likewise, if you click on a third-party link or ad on our website, you will be transferred away from our website and onto the third party’s site. The companies that control third party internet sites, mobile applications, and services may collect your IP address and information that originated from our services and set cookies to enable their features to function and track your usage. Any links we may provide to third-party websites, mobile applications, or social media platforms, are not endorsements of their contents, and we are in no way responsible for them or your use of them. Your interactions with any Third-Party Social Media Services and third-party websites, mobile applications and services are governed by their respective terms, conditions and policies, which you should consult before submitting or allowing any collection of personal information by them.

8. Protection of Personal Information.

We use commercially reasonable security procedures and practices appropriate for the nature of the personal information we collect. However, we cannot guarantee your personal information will be completely secure from unauthorized access, disclosure, use, or alteration. Electronic storage and transmission of information inherently involves risk. To protect the security of any accounts you may use on our or any of our brands’ websites, we recommend you use a complex password that is different from ones you use elsewhere, do not share them with others, and, if written down, store them securely. Remember to log out when you finish using your account to prevent others from accessing your information.

We will NEVER ask your social security number, taxpayer identification number or similarly sensitive private security information. If you are ever asked to provide such information, it will not be by us. We are not in any way responsible for information you share with third parties, including when making transactions and using your credit and debit cards. We encourage you to follow established security protocols and verify the identities of any parties you share information with in any online transaction.

9. International Users.

Our and our brands’ services are intended for users in the United States of America. If you reside or are located in a different country, the legal protections that apply to your personal information may differ from those under U.S. law. Be aware that when you provide or we obtain your personal information in connection with your use of any of our websites or services, it is transferred to our location in the United States and processed according to U.S. law and the terms of this Privacy Policy.

10. Changes to this Privacy Policy.

We may amend this Privacy Policy at any time. If we make a material change to the way we collect, use or share your personal information, we will post a notice on our website. If you continue to use any of our sites or services after such a change, you are consenting to be legally bound to the revised Privacy Policy, whether you have read it or not. We encourage you to check this page regularly for updates.

11. How to Access and Manage Your Personal Information.

You can correct, update, or make changes to the information we have about you by contacting us using one of the methods in the section titled “How to Contact Us” below. You may request we not use your information to provide services to you by emailing us at privacy@sovosbrands.com or by postal mail to the address below.

12. How to Contact Us.

Please direct your account changes and questions and concerns regarding this Privacy Policy and your personal information by:

• email to: privacy@sovosbrands.com; or
• mail to: Sovos Brands
  • 1901 4^th Street, Suite 200
  • Berkeley, California, U.S.A. 94710
  • Attention: General Counsel

13. Notices and Rights for California Consumers.

This section provides additional information under the California Consumer Privacy Act of 2018, as amended (the “CCPA”), and other California consumer protection laws. This section applies only to consumers who reside in the State of California; it does not apply to personal information we collect about our personnel in our role as their employer or to personal information of California residents which we may collect through our business-to-business communications in connection with their role in their employer’s organization. For the purposes of this section, “personal information” also includes information that can reasonably identify a specific household as well as a specific individual.

Notice of Collection of Personal Information.

The personal information we collect about consumers and the business or commercial purposes we use it for are described in the following sections of our Privacy Policy:

• Section 1. What this Privacy Policy Covers.
• Section 2. Personal Information We Collect.
• Section 3. How We Use Personal Information.
• Section 4. When and Why We Share Personal Information and Who We Share It With.

Your Right to Opt-Out of Sale of Personal Information.

Under the CCPA, a California resident is entitled to instruct a business that sells consumers’ personal information not to sell his or her own personal information. We DO NOT sell your personal information.

The CCPA also gives California residents a right to know about personal information collected, disclosed and sold by covered businesses and a right to request deletion of certain personal information. Instructions for how to exercise those rights are below.

Your Right to Know the Personal Information We Collect, Disclose, or Sell.

California residents have the right to know the following about the personal information a covered business has collected, disclosed or sold about him or her or about his or her household:

• Categories Collected in the Last 12 Months: For a description of the types of information we have collected in the last 12 months, see Section 2 (“What Information We Collect”) above.
• Sources of Personal Information: A description of the sources we collect information can be found in Section 2 (“What Information We Collect”) above, particularly in the subsection titled “How We Collect Personal Information.”
• Business Purposes for which Personal Information Is Collected: The purposes for which we collect personal information are described in Section 3 (“How We Use Personal Information”) above.
• Business Purposes for which Personal information Is Sold: As noted above, we do not sell your personal information.
• What Third Parties We Share Personal Information With and the Business Purposes for Sharing It: We may share any one or more, or all, of the categories of personal information described in Section 2 above for any of the purposes and with any of the third parties described in Section 4 (“When and Why We Share Personal Information and Who We Share It With”) above.

If you are a California resident, you have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (the “Right to Know”), subject to certain legal restrictions.

You may submit a Right to Know request by emailing privacy@sovosbrands.com and including “California Right to Know Request” in the subject line.

Your Right to Delete Personal Information.

California consumers also have the right to request that we delete any personal information about them we may have collected, subject to certain exclusions permitted by law (“Right to Delete”). For example, we are not required to delete personal information if it is needed to complete a transaction, reasonably used for an ongoing business relationship, or used internally in a lawful manner compatible with the context in which you provided the information.

If a Right to Delete request is confirmed and verified, we will delete the information from our records and direct any relevant service providers to do the same, unless an exclusion applies. If we are unable to fulfill all or part of your request, we will let you know why (for example, if the information is subject to an exclusion or the requesting person’s identity cannot be verified).

You may submit a Right to Delete request by emailing privacy@sovosbrands.com and including “California Right to Delete Request” in the subject line.

How to Make a Verifiable California Consumer Request.

Before we can respond to a Right to Know or a Right to Delete request, we are required to verify the identity and authority of the person submitting it (and, for requests made by an agent, their relationship with the individual on whose behalf the request is made). Thus, we may require confirmation of certain information, including your email address, phone number, full name, address and other personal information. We reserve the right to deny a verifiable request if the identity or authority of the requesting party cannot be confirmed.

How We Will Respond to a California Consumer Request.

We will confirm receipt of any Right to Know or Right to Delete request within 10 days of receipt and respond to it within 45 days of receipt, subject to delays and exclusions permitted by law. We may request additional information to verify that you are permitted to make the request. If we require more than 45 days to respond, we may extend the response time by up to 45 additional days, in which case we will notify you in writing of the extension and the reason for it. We will respond using the email or postal address provided in the request.

For a Right to Know request, our response will cover the 12-month period preceding our receipt of the request. If we cannot comply with all or part of your request, we will provide an explanation. For requests to provide data, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information readily from one entity to another.

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

Right to Designate an Authorized Agent.

You as a California resident you have the right to designate an authorized agent to submit an Opt-Out Right notice, a Right to Know request or Right to Delete request. This may be a person or business registered with the California Secretary of State. An agent must submit written proof of its authority. You may submit verifiable consumer requests on behalf of your minor children.

Protection from Discrimination for Exercising California Consumer Rights.

We will not discriminate against a California consumer for exercising any of the rights described in this section. This means that (except as legally permitted) we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services (including by granting discounts or other benefits, or imposing penalties);
• Provide you a different level or quality of goods or services; or
• Suggest that your prices, rates or quality of goods or services will differ.

Financial Incentive Programs.

California law allows businesses to offer certain financial or service incentives to encourage consumers to provide certain information. If we wish to begin selling personal information and offer you such a benefit program, we will provide a written “Notice of Financial Incentive” describing its material terms, and you will only be enrolled if you affirmatively opt in to the program. You may revoke that opt-in at any time. Any Notice of Financial Incentive will explain the process for opting in and out of the program. As mentioned above, though, we do not sell any personal information at this time.

California “Shine the Light” Law.

Under California Civil Code §1798.83, California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and receive, once per calendar year, information about the customer information shared, if any, with other businesses for their direct marketing uses. The requesting resident is provided the categories of customer information and the names and addresses the businesses that acquired it in the prior calendar year. You may request this information by contacting us as provided in the “How to Contact Us” section above and indicating “Request for California Privacy Information – Shine the Light Law.” Not all sharing is covered by the “Shine the Light” law; only covered information-sharing will be included in any response.