RICH PRODUCTS PRIVACY POLICY

Rich Products Corporation and our affiliates and subsidiaries (hereinafter referred to as “Rich’s,” “us,” “we,” “our,” or “Company”) has created this Privacy Policy to describe, among other things, the types of personal information we collect, how we use it, and how you can access your information. We collect information about you in a variety of ways depending on how you interact with us and our products and services, including through our websites, social media pages, online and mobiles services, and through our business relationships (hereinafter referred to as our “Services”). Some of the information we collect may include personal information that can be used to identify you. In the event that you apply for a position with Rich’s, your information will be handled in accordance with the Candidate Privacy Policy.

This Privacy Policy is integrated into our Terms & Conditions of Use (“Terms & Conditions”) and explains how we will process your personal information when you make contact with us or use our Services.

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, or the European Union (EU), European Economic Area (“EEA”), and UK, you may be entitled to certain individual rights under the California Consumer Privacy Act of 2018 [as amended by the California Privacy Rights Act of 2020 (“CPRA”)] (collectively, “CCPA”), Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), Utah Consumer Privacy Act (“UCPA”), Texas Data Privacy And Security Act (“TDPSA”), or the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 respectively. Please see the Notice to Certain Residents of Data Subject Rights Section of our Privacy Policy for your rights and how to exercise them for users located in California, Virginia, Colorado, Connecticut, Utah, Texas, and the EEA and UK only.

I. INFORMATION WE COLLECT ABOUT YOU

We may collect the following categories of information about you which are described in more detail below: (A) information you provide to us, (B) sensitive information, (C) information we may automatically collect, and (D) information we may receive from third parties. All of the information listed in (A)-(D) above, is detailed below, and hereinafter referred to as “Information.”

A. Information You Provide to Us

In using our Services, you may provide us with Information, including, without limitation:

Individual identifiers such as name, username, and contact information such as mailing address, phone number, and email address;
Payment and transactional information such as Services purchased. Note that we may use third-party payment processors to facilitate your payments;
Demographic information such as gender and birthdate;
Communications with us, preferences, and other Information you provide to us such as any messages (including via online chat feature), opinions and feedback that you provide to us, your user preferences (such as in receiving updates or marketing information or information related to career opportunities from our Rich’s Careers page), and other Information that you share with us when you contact us directly (such as for support services); and
Additional Information as otherwise described to you at the point of collection or pursuant to your consent.

B. Sensitive Information

We may process the following categories of sensitive personal Information when you use our Services:

Geolocation data; and
Financial account log-in information.

C. Information We May Automatically Collect About You

Our Services may automatically collect the following categories of usage and technical Information about you. This Information is used by Rich’s for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Services.This Information may include:

IP address, which is the number associated with the service through which you access the Internet, like your ISP (internet service provider);
Date and time of your visit or use of our Services;
Domain server from which you are using our Services;
Type of computer, web browsers, search engine used, operating system, or platform you use;
Data identifying the web pages you visited prior to and after visiting our website or use of our Services;
Your movement and activity within the website, which is aggregated with other Information;
Mobile device Information, including the type of device you use, operating system version, and the device identifier (or “UDID”); and
Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.

D. Information We May Receive from Third Parties

We may collect additional Information about you from third-party websites, social media platforms, such as but not limited to, Facebook, Twitter, LinkedIn, or Instagram (“Social Media Platforms”) and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes.
This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

II. Cookies & Technologies Used to Collect Information About You

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this information by using certain technologies, some of which are described in more detail below, such as cookies, web beacons, pixels, software developer kits, third party libraries, and other similar technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. 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 Services. 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.
Session Replay. Session replay is third-party software on our sites and applications which record visitors’ mouse clicks, keystrokes, search terms, and other ways in which you interact with the Services. The use of this technology may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf.
Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf. Our Services use retargeting pixels from Google, Facebook, and other ad networks. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.
Analytics. Analytics are tools we may use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. You can view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms – Google.
Mobile Application Technologies. If you access our website and Services through a mobile device, we may automatically collect Information about your device, your phone number, and your physical location.

Our use of online tracking technologies may be considered a “sale” or “sharing” under certain laws. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under certain laws, you can opt out of these online tracking technologies by submitting a request via Rich’s Privacy Web Form or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC). Please note that some features of our website may not be available to you as a result of these choices.

III. HOW WE USE YOUR INFORMATION

A. Use and Purpose of Processing Your Information

We use and process your Information for things that may include, but are not limited to, the following:

To provide you with the Services and Information you request;
To respond to your inquiries and questions and provide customer service;
To process your product sample or rebate request;
To fulfill transactions and process your registration, orders, and payments across Rich’s ecommerce platform and Rich’s portals;
To send you our newsletter and other correspondence you request;
To help you locate retailer, distributor, and wholesaler location near you;
For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted out of receiving such communications;
To fulfill contracts we have with you;
To manage, improve, and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
To maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services;
To comply with our Terms & Conditions;
Analytics for business purposes and business intelligence;
To verify the accuracy of Information you provide in conjunction with any application to a position with Rich’s, evaluate your candidacy for a position, and complete our recruitment process;
To comply with any applicable laws and regulations and respond to lawful requests; and/or
For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

We may also use Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

IV. Sharing or Disclosing Your Information

We may share and/or disclose your Information as set forth in the Privacy Policy and in the following circumstances:

Third-Party Service Providers. We may share your Information with third-party service providers that perform certain functions or services on our behalf (such as to host the Services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Information only as necessary to provide these services to us. In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Information to identify you individually.
Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates, and any of their officers, directors, employees, attorneys, agents, contractors, and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
Business Transfers. Your Information may be transferred, sold, or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize. You agree to any and all such Conveyances of your Information. We also share your Information with prospective purchasers to evaluate the proposed transaction.
Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates. If you do not want us to share your Information with our subsidiaries and affiliates, please contact privacy@rich.com or call 1-877-352-0077.
De-Identified or Aggregated Data. We may share your Information on an aggregated basis for any purpose in which your specific personal Information is blinded, masked, or otherwise not identifiable.
Online Communications. Any Information you submit in a public forum (e.g., a blog or social network) may be read, collected, or used by us and other participants, and could be used to personalize your experience. You are responsible for the Information you choose to submit in these instances. We may also decide to allow users to participate in surveys or provide us with information regarding their experience.
Advertising Partners. We may share your Information with third parties that support our advertising and marketing efforts, including for the purposes of behavioral advertising.
Professional Advisors. We may share your Information with our professional advisors.
With Your Consent. We may share Information consistent with this Privacy Policy with your consent.

V. Categories of Information Sold

We may sell the below categories of personal Information. For purposes of this Privacy Policy, “sell,” “sold,” or “sale” means the disclosure of personal Information for monetary or other valuable consideration but does not include, for example, the transfer of personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

Category of Information	Examples of Information Disclosed
Identifying Information	Name, mailing address, email address, phone number, date of birth, and other identifiers.
Payment Information	Your name and billing totals for payment and invoice processing. Note that we use third-party payment processors to facilitate your payments and do not store your payment card information.
Usage and Technical Information	Information about your interaction with our website and content on third-party sites or platforms, such as social networking sites (e.g., IP address; browsing history; search history; device information; information about user’s interaction with website, such as scrolling, clicks, and mouse-overs via cookies, pixel tags, web beacons, transparent GIFs; browser information; operating system and platform; geolocation information; user content (e.g., photos, videos, audio, images, social media /online posts, first-party works).

VI. LINKS TO OTHER WEBSITES

Our Services may contain links to other websites or services that are not owned or controlled by us, including links to Social Media Platforms such as Facebook, LinkedIn, Twitter, Instagram, or YouTube, or may redirect you off our website away from our Services.

This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

VII. INFORMATION SECURITY

We use commercially reasonable and appropriate administrative, physical, and technical security measures to provide our Services and safeguard your Information. However, no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you should promptly Contact Us so that necessary measures can quickly be taken.

VIII. DATA RETENTION

We will retain your Information for as long as needed to provide you Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

In the event you apply for a position with Rich’s, we will retain your data as described in the Candidate Privacy Policy. Additionally, in the event you accept a position with Rich’s, we will retain your data for the duration of your employment with us, and for a period of time thereafter, as set forth in the Associate Privacy Policy.

IX. YOUR CHOICES

A. Marketing Communications. If you have consented to receive marketing communications and no longer want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt out of marketing email communications or see How to Contact Us below for more information.

B. Opting Out of Direct Marketing by Third Parties. To exercise choices regarding the marketing information you receive, you may also review the following links:

You may opt out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.
You may opt out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.
You can opt out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

C. Cookies and Similar Tracking Technologies. Most web browsers allow you to reject or delete cookies through their settings preferences. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites. For more information about how certain of our websites use cookies and, where applicable, to update your preferences, click the “Cookie Settings” link available on the applicable website.

D. Opt Out of Targeted Advertising/Sharing. We recognize the Global Privacy Control (GPC) signal and other user-enabled opt-out preference signals as valid opt-out requests where required by applicable law. Please note that your opt-out preference signal will be applied only to your current browser and device. To learn more about the GPC, you can visit its website here.

X. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS

A. NOTICE TO CALIFORNIA RESIDENTS

To the extent any California data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the rights that California residents may have, and how they can exercise those rights. This notice applies solely to California residents. We provide the supplemental section below to comply with the California Consumer Privacy Act [as amended by the California Privacy Rights Act (referred to collectively hereinafter as CCPA)] and any terms defined in the CCPA have the same meaning when used below.

1. Your Rights under CCPA

Right to Know and Access Specific Information. You have the right to request that we disclose certain information to you about our collection and use of your Information over the past twelve (12) months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you, to the extent permitted by law:

- The categories of Information we collected about you, and whether we sell or share your Information to third parties.
- The specific pieces of Information we hold about you.
- The categories of personal Information sold within the last twelve (12) months.
- The categories of sources from which Information about you is collected.
- Our business or commercial purpose for collecting, selling, or sharing your Information.
- The categories of third parties with whom your Information is sold, shared, or disclosed for a business purpose.

You have the right to request that the Information described above be provided to you in a commonly used, machine-readable format, to the extent technically feasible.

Deletion Request Rights. You have the right to request that we delete the Information that we collected from you, subject to certain exceptions. To the extent that we can delete your Information, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Information, unless an exception applies.

Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal Information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your verifiable consumer request, we will use commercially reasonable efforts to correct your personal Information, if we find that it is inaccurate.

Sale and Sharing of Personal Information and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:
- Sale of your Information.
- Sharing of your Information for cross-context behavioral advertising.

The use of online tracking technologies may be considered a “sale” or “sharing” under California law. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under California law, you may opt out of these online tracking technologies by submitting a request via Rich’s Privacy Web Form or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC).

Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the ways we use and disclose your sensitive personal Information (as defined by CCPA) to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or and as authorized by law.
Right to Non-Discrimination. You have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We may not, and will not, treat you differently because of your data subject request activity. As a result of your data subject request activity, we may not and will not deny goods or Services to you, charge different rates for goods or Services, provide a different level quality of goods or Services, or suggest that we would treat you differently because of your data subject request activity.

Right to Disclosure of Direct Marketers. You have a right to the categories and names/addresses of third parties that have received your personal Information for their direct marketing purposes upon simple request, and free of charge.

You may make an authenticated consumer request exercising your Right to Know and Access Specific Information including Right to Know what Personal Information is being Sold or Shared or under the CCPA twice within a twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant to California Probate Code sections 4000 to 4665. We may deny a request from an authorized agent that does not submit proper verification proof.

3. Notice of Financial Incentive

As an incentive for providing us with your Information, you may receive a financial benefit in the form of an email coupon, discount, rebate, free sample, promotions, or other similar reward that will be sent to you. This discount may constitute a financial incentive under the California Consumer Privacy Act (“Financial Incentive”). The categories of personal Information required for us to provide the Financial Incentives include personal identifiers such as full name and contact information including email address as well as personal and demographic information you choose to provide.

To offer these discounts, we may track your personal Information, such as purchase history and other demographic data. You have the right to withdraw from the Financial Incentive at any time by submitting a request to privacy@rich.com. Please note that if you request deletion of part or all your personal Information, that could affect your ability to qualify for the discount.

4. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

B. NOTICE TO VIRGINIA RESIDENTS

To the extent any Virginia data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights guaranteed to Virginia residents and how to exercise those rights and applies solely to Virginia residents. We provide the supplemental section below to comply with the Virginia Consumer Data Protection Act (“VCDPA”) and any terms defined in the VCDPA have the same meaning when used below.

1. Your Rights under VCDPA

Subject to certain exceptions you may be entitled to the following rights:

Right to Access & Data Portability.. You have the right to request that we disclose certain information to you about our collection and use of your Information at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:
- Disclose whether we are processing your Information.
- Provide you with access to your Information.

Where the processing is carried out by automated means, and subject to certain exceptions, you have the right to request and obtain a copy of your Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Information to another data controller without hindrance.

Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate Information, you have the right to request that we correct such inaccurate Information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your authenticated consumer request, we will use commercially reasonable efforts to correct your Information.
Right to Delete. You have the right to request that we delete certain of your Information provided by or obtained about you. To the extent that we can delete your Information, once we receive and confirm your authenticated consumer request, we will delete (and direct our service providers to delete) your Information, subject to certain exceptions.

Sale of Personal Information, Targeted Advertising, Profiling, and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:

- Targeted advertising.
- Sale of your Information.
- Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Appeal. You have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeals request via the information in the How To Contact Us section below. Within sixty (60) days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Virginia Office of the Attorney General by:
- Contacting Online: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint
- Calling:

- If calling from Virginia, call the Consumer Protection Hotline at 1-800-552-9963.
- If calling from the Richmond area or from outside Virginia, call the Consumer Protection Hotline at 1-804-786-2042.

Right to Non-Discrimination. You have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We will not discriminate against you for exercising any of your rights in this section including denying goods or Services, charging different prices or rates for goods or Services, or providing a different level of quality of goods and Services. However, we may offer a different price, rate, level, quality, or selection of goods or Services, including offering goods or Services for no fee, if you have exercised your right to opt out or the offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

You may make an authenticated consumer request under the VCDPA twice within a twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

C. NOTICE TO COLORADO RESIDENTS

To the extent any Colorado data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights guaranteed to Colorado residents and how to exercise those rights and applies solely to Colorado residents. We provide the supplemental section below to comply with the Colorado Privacy Act (“CPA”) and any terms defined in the CPA have the same meaning when used below.

1. Your Rights under CPA

Subject to certain exceptions you may be entitled to the following rights:

Right to Access & Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Information at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:
- Disclose whether we are processing your Information.
- Provide you with access to your Information where we process it.

Where exercising your right to access, you have the right to request and obtain a copy of your Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Information to another data controller without hindrance (“data portability”).

Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal Information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your authenticated consumer request, we will use commercially reasonable efforts to correct your personal Information.
Right to Delete. You have the right to request that we delete certain of your Information provided by or obtained about you. To the extent that we can delete your Information, once we receive and confirm your authenticated consumer request, we will delete your Information, subject to certain exceptions.

Sale of Personal Information, Targeted Advertising, Profiling, and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:
- Targeted advertising.
- Sale of your Information.
- Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to Appeal. You have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeals request via the information in the How To Contact Us section below. Within forty-five (45) days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If you have concerns regarding the results of your appeal, you may contact the Colorado Office of the Attorney General by:

- Contacting Online: https://complaints.coag.gov/s/contact-us
- Calling: (720) 508-6000

You may make an authenticated consumer request free of charge under the CPA once within a twelve (12) month period. We reserve the right to charge a reasonable fee for a second or subsequent request within the same twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Sensitive Data

We do not process sensitive data including sensitive data inferences. When we process sensitive data, we do so with your consent.

3. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf. An authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant to Colo. Rev. Stat. § 15-14-705. We may deny a request from an authorized agent that does not submit proper verification proof.

4. Notice of Financial Incentive

As an incentive for providing us with your Information, you may receive a financial benefit as part of our bona fide loyalty program in the form of an email coupon, discount, rebate, free sample, promotions, or other similar reward that will be sent to you. This discount may constitute a financial incentive under the Consumer Privacy Act (“Financial Incentive”). The categories of personal Information required for us to provide the Financial Incentives include personal identifiers such as full name and contact information including email address as well as personal and demographic information you choose to provide.

D. NOTICE TO CONNECTICUT RESIDENTS

To the extent any Connecticut data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights guaranteed to Connecticut residents and how to exercise those rights and applies solely to Connecticut residents. We provide the supplemental section below to comply with the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”) and any terms defined in the CTDPA have the same meaning when used below.

1. Your Rights under CTDPA

Subject to certain exceptions you may be entitled to the following rights:

Right to Access & Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Information at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:

- Disclose whether we are processing your Information.
- Provide you with access to your Information where we process it.

Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal Information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your authenticated consumer request, we will use commercially reasonable efforts to correct your personal Information.
Right to Delete. You have the right to request that we delete certain of your Information provided by or obtained about you. To the extent that we can delete your Information, once we receive and confirm your authenticated consumer request, we will delete (and direct our service providers to delete) your Information, subject to certain exceptions.

Sale of Personal Information, Targeted Advertising, Profiling, and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:

- Targeted advertising.
- Sale of your Information.
- Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Non-Discrimination. You have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We will not discriminate against you for exercising any of your rights in this section including denying goods or Services, charging different prices or rates for goods or Services, or providing a different level of quality of goods and Services. However, we may offer a different price, rate, level, quality, or selection of goods or Services, including offering goods or services for no fee, if you have exercised your right to opt out or the offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

Right to an Appeal. You have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeals request to us by either:

- Emailing us at privacy@rich.com

- Calling us at 1-877-352-0077

Within sixty (60) days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Connecticut Office of the Attorney General by:

Contacting Online: https://www.dir.ct.gov/ag/complaint/e-complaint.aspx?CheckJavaScript=1
Calling: The Consumer Assistance Unit at 860-808-5420

You may make an authenticated consumer request under the CTDPA once within a twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf. An authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, including through technological means, and identity verification from you; or (2) proof of power of attorney. We may deny a request from an authorized agent that does not submit proper verification proof.

3. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

E. NOTICE TO UTAH RESIDENTS

To the extent any Utah data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights guaranteed to Utah residents and how to exercise those rights and applies solely to Utah residents. We provide the supplemental section below to comply with the Utah Consumer Privacy Act (“UCPA”) and any terms defined in the UCPA have the same meaning when used below.

1. Your Rights under UCPA

Subject to certain exceptions you may be entitled to the following rights:

Right to Access & Data Portability. You may have the right to request that we disclose certain information to you about our collection and use of your Information at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:

- Disclose whether we are processing your Information.
- Provide you with access to your Information where we process it.

Right to Delete. You have the right to request that we delete certain of your Information provided by or obtained about you. To the extent that we can delete your Information, once we receive and confirm your authenticated consumer request, we will delete (and direct our service providers to delete) your Information, subject to certain exceptions.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights in this section including denying goods or Services, charging different prices or rates for goods or Services, or providing a different level of quality of goods and services.
Sale of your Personal Information, Targeted Advertising, and Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:

- Targeted advertising.
- Sale of your Information.

You may make an authenticated consumer request free of charge under the UCPA once within a twelve (12) month period. We reserve the right to charge a reasonable fee for a second or subsequent request within the same twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

F. NOTICE TO TEXAS RESIDENTS

To the extent any Texas data privacy law applies to the collection of your Information, this supplemental section of our privacy policy outlines the individual rights guaranteed to Texas residents and how to exercise those rights and applies solely to Texas residents. We provide the supplemental section below to comply with the Texas Data Privacy and Security Act (“TDPSA”) and any terms defined in the TDPSA have the same meaning when used below.

1. Your Rights Under TDPSA

Subject to certain exceptions you may be entitled to the following rights:

Right to Access & Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Information at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:

- Disclose whether we are processing your Information.
- Provide you with access to your Information where we process it.

Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal Information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your authenticated consumer request, we will use commercially reasonable efforts to correct your personal Information.
Right to Delete. You have the right to request that we delete certain of your Information provided by or obtained about you. To the extent that we can delete your Information, once we receive and confirm your authenticated consumer request, we will delete your Information, subject to certain exceptions
Sale of Personal Information, Targeted Advertising, Profiling, and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:

- Targeted advertising.
- Sale of your Information.
- Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Appeal. You have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeals request via the information in the how to contact us section below. Within sixty (60) days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If you have concerns regarding the results of your appeal, you may contact the Texas office of the attorney general by:

- Contacting online: https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint
- Calling: (800) 621-0508

You may make an authenticated consumer request free of charge under the TDPSA twice within a twelve (12) month period. We reserve the right to charge a reasonable fee for a third or subsequent request within the same twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Sensitive Data

We may process sensitive data. When we process sensitive data, we do so with your consent.

3. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf. An authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney. We may deny a request from an authorized agent that does not submit proper verification proof.

G. NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND THE UK

This section applies only to individuals coming to our Services from within the European Union (EU), the European Economic Area (EEA), and the UK, and only if we collect through the Services any Information from you that is considered “Personal Data,” as defined in the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.

Personal Data includes any information relating to an identified or identifiable natural person, who could be identified either directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person (which may include some or all your Information as defined in this Privacy Policy).

1. Identity and Contact Details of Controller and EU Representative

Unless otherwise stated, we are the Data Controller for the Information we process.

Contact Details:

Email: privacy@rich.com

Call us: +44 03300605174

Write us: Rich Andover Realty Limited

Unit 5 Pioneer Road

Andover Business Park

Andover, GB SP11 8EZ

2. Your Data Protection Rights

To the extent the GDPR and Data Protection Act 2018 apply, and we hold your Information in our capacity as a Data Controller as defined under those laws, you may request that we:

Restrict the way that we process and share your Information;
Transfer your Information to a third party;
Provide you with access to your Information;
Remove your Information if no longer necessary for the purposes collected;
Update your Information so it is correct and not out of date; and/or
Object to our processing of your Information.

You may also revoke your consent for processing of your Information. If you wish to object to the use and processing of your Information or withdraw consent to this Privacy Policy, you can contact us in the following ways:

Email: privacy@rich.com

Call us: +44 (0)330 060 5100

Write us: Rich Andover Realty Limited
Unit 5 Pioneer Road
Andover Business Park
Andover, GB SP11 8EZ

We have also appointed a Data Protection Officer (DPO) for the EEA and UK. You can contact the DPO at ukdpo@rich.com.

The requests above will be considered and responded to in the time period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional Information from you to confirm your identity in responding to such requests.

You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Otherwise, you may contact the UK Information Commissioner’s Office by the following means:

Form: www.ico.org.uk/global/contact-us/email/

Telephone: 0303 123 1113.

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire
SK9 5AF

3. Lawful Basis for Processing Your Information

The lawful basis for our processing of your Personal Data will depend on the purpose of the processing. For most Personal Data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for our legitimate business interests. Where we process Personal Data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. If we are required to share Personal Data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device.

Depending on what Personal Data we collect from you and how we collect it, we may also rely on various grounds for processing your Personal Data, including the following reasons:

Processing on the basis of legitimate business interests. When we process Personal Data on the basis that the processing is necessary for our legitimate business interests, such interests include: (i) providing, improving, and promoting our Services; (ii) communicating with current and potential customers, candidates for employment with Rich’s, other business partners, and their individual points of contact; (iii) managing our relationships with our customers and other business partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information within the Company, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our products, Services, and employees, including fraud protection.
Processing on the basis of performance of a contract. Examples of situations in which we process Personal Data as necessary for performance of a contract include e-commerce transactions in which you purchase a service from us.
Processing on the basis of consent. Examples of processing activities for which we may use consent as its legal basis include: (i) collecting and processing precise location information from your mobile device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing Personal Data on Company Services through cookies and similar technologies when consent is required by applicable law.
Processing because we are under a legal obligation to do so. Examples of situations in which we must processes Personal Data to comply with our legal obligations include: (i) providing your Personal Data to law enforcement agencies and other governmental bodies when required by applicable laws; (ii) retaining business records required to be retained by applicable laws; and (iii) complying with court orders or other legal process.

If the processing of your Personal Data is based on your consent, the GDPR and Data Protection Act 2018 also allow users the right to access, revoke, or modify your consent at any time. Please see the How to Contact Us section, below, to review or modify your consents.

4. Consent to Transfer

We are operated in the United States, and we may use service providers based in the United States to operate our business and our relationship with you. Please be aware that Information, including your Personal Data, that we collect will be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We maintain measures to address the transfer of your Personal Data between our group companies and between us and our third-party providers in accordance with applicable data protection laws and regulations.

5. Retention

We will retain your Information for as long as needed for the purposes described in this Privacy Policy. More specifically, the time we maintain your Information depends on the following factors:

Whether we need the Information to provide the Services. We will maintain any data needed to provide you with the Services, such as contact information and payment or transaction information, for as long as needed for us to provide you with the Services, respond to your questions and requests, and/or administer your account (if applicable).
Whether we need the Information to comply with our legal obligations. We may have legal obligations to maintain your Information where a legal or regulatory body may ask for it in the future, for example in response to a data subject request or complaint. This information may include contact information and location information.
Whether we need the Information for a legitimate business interest. We may store Information like contact information, cookies, and location information in order to perform analytics, troubleshoot errors, or improve our Services. In any event, we delete the Information when it is no longer needed for our legitimate interest.

Regardless of our reason for retaining your Information, we delete all Information in accordance with our routine record keeping policies.

6. Modern Slavery Statement

Introduction

This statement sets out the actions that Rich Products Ltd has taken to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year [1 January 2023 to 31 December 2023].

Rich Products Ltd recognises that it has a responsibility to take a robust approach to preventing slavery and human trafficking and is committed to constantly reviewing and improving its practices.

Rich Products Ltd is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure

This statement covers the activities of Rich Products Ltd. Rich Products Ltd supplies bakery products to a diverse range of customers, from leading coffee shop chains to renowned department stores and well-known supermarkets. Rich Products Ltd is registered in England (registered number 1847615).

Supply Chains

Supply chain security and integrity is a crucial component of our business model. Robust technical and traceability systems ensure that our products are responsibly sourced from suppliers whose values are aligned with our own. Every supplier is subject to a rigorous approval process where extensive checks are carried out, both technically and commercially to ensure that the supplier complies with all of our requirements before being approved. Ongoing checks are also carried out on a regular basis either via the use of our quarterly performance scorecard and/or technical audits.

We work to influence suppliers’ practices and where gross violations are uncovered; we would attempt to work with the supplier to correct it in the first instance. If it became apparent that the required improvement is not possible, then a review of the trading relationship would be undertaken.

As a business we use Labour Providers to supply a percentage of our workforce. Each Labour Provider is audited against our own Labour Provider audit standard every 6 months. Within these audits, the ETI Base Code and controls around Modern Slavery are reviewed.

We always monitor, assess, and mitigate the potential risk areas in our supply chains and have robust systems in place to deal with such risks. We provide Supplier Self Audit Questionnaires which include an Ethical Section as per below and have recently implemented the use of a software tool called Tracegains across our Supply base. This software allows us to determine when BRC and specifications are due for renewal in advance of the completion date.

Responsibility

Responsibility for Rich Products Ltd.’s initiatives addressing slavery and human trafficking is as follows.

Responsibility for policies are;

People Support –HR Manager, Rich Products Ltd, for policies related to the prevention of slavery and human trafficking in our own operations.
VP – Compliance, Deputy General Counsel • Legal of Rich Products Corporation, for the Code of Conduct/Ethics globally.
Procurement – Head of Procurement, for ensuring the policies relating to the prevention of slavery and human trafficking in our supply chain are adhered to.

Due Diligence and Mitigating Risk

In our own operations, the People Support team are responsible for ensuring that our company adhere to all employment laws in the due diligence checks undertaken during different stages of employment, from initial recruitment onward.

As part of our initiative to identify and mitigate risk we monitor ethical standards across the business on a regular basis both internally and via external third-party audits. Sites undergo unannounced SEDEX members Ethical Trade Audits every other year. This activity is also supported by our Ethical Trading Policy, our CSR Policy, our Equal Opportunities Policy, and our commitments to ensuring the safety of our associates.

Due Diligence of Suppliers Undertaking

Rich Products Ltd undertakes due diligence when considering its procurement arrangements, and regularly reviews its existing suppliers. Our due diligence and reviews include:

Conducting supplier audits or assessments through the company’s own associates, which have a greater degree of focus on slavery and human trafficking where general risks are identified
Suppliers are required to sign up to the company’s code of conduct
Any UK agency supplier must be registered with the Gangmaster Licencing Abuse Authority
Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular including Stronger Together

Relevant policies

Rich Products Ltd operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

Whistleblowing policy. Rich Products Ltd operates a Whistleblowing Policy which encourages all its associates, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Rich Products Ltd.’s whistleblowing procedure is designed to make it easy for associates to make disclosures, without fear of retaliation.
Code of conduct. This code makes it clear to all associates and suppliers the actions and behaviours expected of them when representing Rich Products Ltd. Rich Products Ltd strives to maintain the highest standards of associate/supplier conduct and ethical behaviour when operating and managing its supply chain.
Supplier/Procurement Code of Conduct. Rich Products Ltd is committed to ensuring that its suppliers adhere to the highest standards of ethics and are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.

Any suppliers we use are pre-qualified using our RFI and SAQ documents and are only approved to the next stage (RFQ or RFP) if they pass our commercial and technical checks. We integrate forced labour policies within our contract and new supplier completion forms through the use of legal clauses and assess and screen those suppliers via the use of our technical approval procedure.

As a minimum requirement, all new suppliers must have BRC Accreditation Grade A, pass our Dun and Bradstreet financial check and must agree to our terms and conditions.

Rich Products Ltd works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. Agencies and suppliers are audited on a regular basis.

Policy for Recruitment / Agency workers. Rich Products Ltd operates a robust recruitment policy, including conducting eligibility to work in the UK checks for all associates to safeguard them against human trafficking or individuals being forced to work against their will. Rich Products Ltd will only use specified, reputable employment agencies which have been audited to source labour and always verifies the practices of any new agency it is using before accepting associates from that agency. Agencies are audited by People Support every six months. In the event of any risk being identified in respect of any worker, they would be spoken in accordance with the advice provided by ‘Stronger Together’ and further advice would immediately be sought from the Gangmaster and Labour Abuse Authority if it were deemed to be necessary.
ETI Base Code/Ethical Trade Policy. Rich Products Ltd complies with the Ethical Trading Initiative (ETI) Base Code and enforces its Ethical Trade policy. Rich Products Ltd recognises the importance of being aware of labour practices in its supply chain and the need to monitor, evaluate and act on information about our suppliers and their sub-contractors’ performance. Only agencies holding a GLA (Gangmaster Licensing Authority) license are used for the supply of temporary labour.

Rich Products is also registered with SEDEX (the largest collaborative platform for sharing ethical supply chain data).

Anti-Slavery Policy. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Bullying and Harassment Policy. Rich Products are committed to providing a work environment that is free from bullying and harassment in which individuals to not feel threatened or intimidated. This policy covers everyone working at Rich Products including agency labour. This policy also refers to victimisation which is also prohibited.
Equal Opportunities Policy. Rich Products are committed in promoting an ethos and culture of diversity, equality, and inclusion. We aim to create a working environment in which all individuals are able to make the best use of their skills free from discrimination and harassment and in which all decisions are based on merit

Training and awareness building

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will provide any required training to our staff and agency staff. Our People Support team have attended the ‘Stronger Together – Tackling Modern Slavery in Supply Chains’ workshops. People Support have been using Responsible Recruitment tool kit and this has involved going on Induction to Responsible Recruitment and Fair and Equal Opportunity and treatment.

All managers are responsible for ensuring that all associates of Rich Products Ltd are aware of the risks and signs of slavery and human trafficking, and of the company’s responsibilities under the Modern Slavery Act 2015.

Approval for this statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31 December 2023 and has been approved on the 02^nd October 2024.

CEO (UK) Name: Elizabeth Kobilski

Date: 02^nd October 2024

7. Terms & Conditions Of Purchase

1. DEFINITIONS & INTERPRATION

1.1 In these Terms and Conditions the following expressions will have the following meanings unless inconsistent with the context:
“Business Day” any day other than a Saturday or Sunday or a public or bank holiday in England or Wales.
“Company” Rich Products, Andover Business Park.
“Company Materials” all materials, equipment and tools, drawings, specifications and data supplied by the Company to the Seller.
“Confidential Information” all information in respect of the business of the Company including, but not limited to, know-how or other matters connected with the Goods and/or Services, and information concerning the Company’s relationships with actual or potential clients, customers or suppliers and the needs and requirements of the Company and of such persons and any other information which, if disclosed, will be liable to cause harm to the Company.
“Contract” any contract between the Company and the Seller for the sale and purchase of the Goods formed in accordance with Condition 2.
Delivery Date” the date specified in the Order.
“Delivery Location” the address for delivery of the Goods and/or for the performance of the Services as set out in the Order.
“Deliverables” all documents, products and materials developed by the Seller or its agents, contractors and employees as part of or in relation to the Services in any form or media, including drawings, maps, plans, diagrams, designs, pictures, computer programs, data, specifications and reports (including drafts).
“Force Majeure” any cause preventing the Company from performing any or all of its obligations which arises from or is attributable to acts, events, omissions or accidents beyond the reasonable contemplation and control of the Company including, without limitation, strikes, lockouts or other industrial disputes (whether involving the work force of the Company or otherwise), protest, act of God, war, national emergency, an act of terrorism, riot, civil commotion, malicious damage, compliance with any law or governmental order, rule, regulation or direction, accident, breakdown of plant or machinery, fire, explosion, flood or storm, epidemic or default of suppliers or subcontractors.
“Goods” any goods which the Seller supplies to the Company (including any of them or any part of them) under a Contract.
“Intellectual Property Rights” all intellectual and industrial property rights including patents, know-how, registered trade marks, registered designs, utility models, applications for and rights to apply for any of the foregoing, unregistered design rights, unregistered trade marks, rights to prevent passing off for unfair competition and copyright, database rights, topography rights and any other rights in any invention, discovery or process, in each case in the United Kingdom and all other countries in the world and together with all renewals and extensions
“Mandatory Policies” The Company’s business policies and codes as amended by notification by the Seller from time to time.
“Order” the Company’s order for the Goods and/or Services, as set out in the Company’s purchase order form.
“Seller” the person(s), firm or company from whom the Company orders the Goods and/or Services.
“Services” the services, including any Deliverables, to be provided by the Supplier under the Contract as set out in the Specification.
“Specification” in relation to any Goods, the technical specifications of those Goods; all ingredient lists and health and safety requirements; all preparatory, design and development materials which relate to the Goods; all information of any description which explains how the Goods are to be stored and/or packaged, and in relation to any Services, the description or specification for Services agreed in writing by the Company and the Seller.
“Terms and Conditions” the standard terms and conditions of purchase set out in this document, as amended from time to time in accordance with Condition 2.4.
1.2 The headings in these Terms and Conditions are for convenience only and will not affect their construction or interpretation. A reference to a statute or statutory provision is a reference to such statute or provision as amended or re-enacted. A reference to a statute or statutory provision includes any subordinate legislation made under that statute or statutory provision, as amended or re-enacted. Any phrase introduced by the terms including, include, in particular or any similar expression shall be construed as illustrative and shall not limit the sense of the words preceding those terms. A reference to writing or written includes emails.

2. FORMATION

2.1 Subject to any variation in accordance with these Terms and Conditions, the Contract will be upon these Terms and Conditions to the exclusion of all other terms and conditions, including any terms or conditions which the Seller purports to apply under any acknowledgement or confirmation of order, quotation, Specification, delivery note, invoice or similar document, whether or not such document is referred to in the Contract.
2.2 Each quotation for the Goods and/or Services from the Seller will be deemed to be an offer by the Seller to sell the Goods and/or Services upon these Terms and Conditions. All quotations provided by the Seller, including the price provision, will remain open for 90 days from its date. The Contract is only formed when a written acceptance of the quotation in the form of an Order or in any other written form is served by the Company on the Seller. No contract will exist prior to service of such notice of acceptance.
2.3 Delivery of the Goods (as described in Condition 6.4), and/or performance of the Services (as described in Condition 4) will be deemed conclusive evidence of the Seller’s acceptance of these Terms and Conditions.
2.4 Save as set out in the Contract, these Terms and Conditions (including any special terms and conditions agreed between the parties) may only be varied or amended in writing and signed by a duly authorised representative of the Company.

In no event shall rich be liable for any special, indirect or consequential damages or damages of any kind resulting from your use of or access to the information or software contained at this web site. The above limitation may not apply to you to the extent that applicable law may not allow the limitation of liability for incidental or consequential damages. In any event, Rich’s total liability to you for all losses, damages and causes of action, whether the damages are claimed under the terms of a contract, or claimed to be caused by negligence or other wrongful conduct, or claimed under any other legal theory, will not be greater than the amount you paid to access this web site.

3. THE GOODS & THE COMPLIANCE

3.1 The quantity and description of the Goods will be as set out in the Order and/or in any applicable Specification supplied or advised by the Seller before the Order.
3.2 The Seller shall ensure that the Goods: (a) correspond with their description and any applicable Specification; (b) be of satisfactory quality (within the meaning of the Sale of Goods Act 1979, as amended) and fit for any purpose held out by the Seller or made known to the Seller by the Company expressly or by implication, and in this respect the Company relies on the Seller’s skill and judgement; (c) where they are manufactured products, be free from defects in design, material and workmanship and remain so for 12 months after delivery, or such shorter period applicable to the shelf-life of the relevant Goods (as the case may be); and (d) comply with all applicable statutory and regulatory requirements relating to the manufacture, labelling, packaging, storage, handling and delivery of the Goods.
3.3 The Seller will, and will procure that its officers, employees, agents, approved sub-contractors and any other persons who perform obligations under or in connection with this Contract: (a) comply with all applicable laws, standards, regulations and/or other legal requirements concerning the manufacture, packaging, packing and delivery of the Goods and shall provide written details of such compliance upon the request of the Company; and (b) comply with the Mandatory Policies.
3.4 The Seller shall ensure that at all times it has and maintains all the licences, permissions, authorisations, consents and permits that it needs to carry out its obligations under the Contract.
3.5 The Company (and any customer of the Company who may use the Goods subsequently in its own products) will have the right to inspect and test the Goods at any time prior to delivery and to inspect the premises from which the Goods are provided. The Seller will not unreasonably refuse any request by the Company (or any third party permitted by this Condition 3.5) to carry out such inspection and testing and will provide the Company or such other third party with all facilities reasonably required.
3.6 If as the result of such inspection or testing the Company is not satisfied that the Goods will comply in all respects with the Contract, the Seller will take all steps necessary to ensure compliance. Without prejudice to any other rights of the Company under the Contract, any failure of this obligation by the Seller will be deemed a material breach which is not capable of remedy entitling the Company to terminate the Contract under Condition 12.1(a).
3.7 For the avoidance of doubt, the Company may conduct further inspections and tests after the Seller has carried out its remedial actions.
3.8 Notwithstanding any such inspection or testing, the Seller will remain fully responsible for the Goods and any such inspection or testing will not diminish or otherwise affect the Seller’s obligations under the Contract.
3.9 The Seller acknowledges that precise conformity of the Goods with the Contract is of the essence of the Contract and the Company will be entitled to the remedies specified in Condition 7. Any breach of this Condition is deemed a material breach which is not capable of remedy under Condition 12.1(a).
3.10 The Company may at any time make changes in writing relating to the Order, including changes in the drawings or Specifications, method of shipment, quantities, packing or time or place of delivery. If such changes result in an increase or decrease in the cost of, or the time required for performance of the Contract an equitable adjustment will be made to the price, delivery schedule or both. Any such claim or adjustment must be approved by the Company in writing before the Seller proceeds with such changes.
3.11 The Seller will maintain and observe quality control and supplier quality assurance standards in accordance with the requirements of the Company (including those of its customers), relevant British Standards and statutory and regulatory bodies. Failure to comply with such standards shall enable the Company to terminate the whole, or any unfulfilled part of any Contract at any time without further liability to the Seller, other than to pay for any Goods which the Company has received and which it does not reject pursuant to any provision of these Terms and Conditions.
3.12 The Seller will maintain detailed quality control and manufacturing records for the period of at least 12 years from the date of supply of Goods.
3.13 In the event that any Goods are either not delivered to the Company, or are returned to the Seller for whatever reason, and such Goods are manufactured, packaged or labelled in such a manner as to identify them in any way with the Company, or a customer of the Company, the Seller shall not under any circumstances, dispose of such Goods to a third party without the prior written consent of the Company. Any specific instructions given by the Company in respect of such disposal shall be strictly adhered to by the Seller and in any event, all references to the Company’s (or customer of the Company’s) name, address, trade marks and any other indications of the Company’s (or customer of the Company’s) identity shall be totally removed by the Seller prior to disposal so that no such reference remains which might lead any third party to associate the Goods with the Company (or any customer of the Company).

4. THE SUPPLY OF THE MARKET

4.1 The Seller shall from the date set out in the Order or such other date as the Company notifies to the Seller, and for the duration of the Contract supply the Services to the Company in accordance with the terms of the Contract.
4.2 The Seller shall meet any performance dates for the Services specified in the Order or that the Company notifies to the Seller.
4.3 In providing the Services, the Seller shall: (a) co-operate with the Company in all matters relating to the Services, and comply with all instructions of the Company; (b) perform the Services with the best care, skill and diligence in accordance with best practice in the Seller’s industry, profession or trade; (c) use personnel who are suitably skilled and experienced to perform tasks assigned to them, and in sufficient number to ensure that the Seller’s obligations are fulfilled in accordance with the Contract; (d) ensure that the Services and Deliverables will conform with all descriptions and specifications set out in the Service Specification, and that the Deliverables shall be fit for any purpose that the Company expressly or impliedly makes known to the Seller; (e) provide all equipment, tools and vehicles and such other items as are required to provide the Services; (f) use the best quality goods, materials, standards and techniques, and ensure that the Deliverables, and all goods and materials supplied and used in the Services or transferred to the Company, will be free from defects in workmanship, installation and design; (g) obtain and at all times maintain all licences and consents which may be required for the provision of the Services; (h) comply with all applicable laws, regulations, regulatory policies, guidelines or industry codes which may apply to the provision of the Services, and with the Mandatory Policies; (i) observe all health and safety rules and regulations and any other security requirements that apply at any of the Company’s premises; (j) hold all Company Materials in safe custody at its own risk, maintain the Company Materials in good condition until returned to the Company, and not dispose or use the Company Materials other than in accordance with the Company’s written instructions or authorisation; (k) not do or omit to do anything which may cause the Company to lose any licence, authority, consent or permission upon which it relies for the purposes of conducting its business, and the Seller acknowledges that the Company may rely or act on the Services; (l) comply with any additional obligations as set out in the Specification.
4.4 The Company shall: (a) provide the Seller with reasonable access at reasonable times to the Company’s premises for the purpose of providing the Services; and (b) provide such necessary information for the provision of the Services as the Seller may reasonably request.

5. PRICE AND PAYMENT

5.1 The price for the Goods and/or Services will be the price stated in the Order, or if no price is quoted, the price set out in the Seller’s published price list in force as at the date the Contract came into existence and, unless otherwise stated in that Order, will be: (a) inclusive of all charges, costs and expenses including, but not limited to, packaging material, packing, shipping, loading, carriage, insurance and delivery of the Goods to the Delivery Location and any duties, imposts, levies or taxes including value added tax; and (b) fixed for the duration of the Contract or for such longer period that may be agreed by the parties in writing.
5.2 No variation in the price nor extra charges or expenses can be made (whether on account of increased material, labour or transport costs, fluctuation in rates of exchange or otherwise) without the prior written consent of the Company. No expenses shall be payable unless the Company has pre-approved in writing such expenses.
5.3 In respect of the Goods, the Seller shall invoice the Company for the Goods within 30 days of delivery. In respect of Services, the Seller shall invoice the Company on completion of the Services. Each invoice must be a valid VAT invoice and quote the number of the Order. Payment is due in sterling within 30 days of receipt by the Company of such valid invoice.
5.4 Payment shall be made to the bank account set out in the Order.
5.5 Without prejudice to any other right or remedy, the Company will be entitled but not obliged at any time or times without notice to the Seller to set off any liability of the Seller to the Company against any liability of the Company to the Seller (in either case however arising and whether any such liability is present or future, liquidated or unliquidated and irrespective of the currency).

6. DELIVERY

6.1 The Seller may not deliver the Goods by separate instalments unless agreed in writing by the Company. If the Company does agree, the Contract will be construed as a separate Contract in respect of each instalment or stage, and without prejudice to any other right or remedy, the Company will have the right, but not the obligation, to: (a) treat all the Contracts for the total Order as repudiated if the Seller fails to deliver or perform any instalment or stage; and (b) reject any or all of the instalments for the total Order if the Company is entitled to reject any one instalment.

6.2 The Goods will be delivered, carriage paid, to the Delivery Location. The Company will off-load the Goods.

6.3 The Goods will be delivered during the Company’s normal office hours on the Delivery Date stated on the Purchase Order.

6.4 Delivery of the Goods shall be completed on the completion of unloading the Goods at the Delivery Location.

6.5 The Seller will ensure that: (a) the Goods are marked in accordance with the Company’s instructions and any applicable regulations or requirements of the carrier and properly packed and stored so as to reach their destination in an undamaged condition; (b) each delivery is accompanied by a prominently displayed delivery note which shows, inter alia, the Order number, date of Order, number of packages and contents and, in the case of part delivery, the outstanding balance remaining to be delivered; and (c) the Company is supplied on delivery of the Goods with all information as may be necessary for their proper use, maintenance and storage for the Company to accept delivery of the Goods.

6.6 No Goods supplied under the Contract earlier than the date for delivery or performance, will be accepted or paid for unless the Company notifies the Seller in writing of its intention to accept and pay for the same.

6.7 Without prejudice to the Company’s other rights under the Contract, if the Goods are delivered to the Company: (a) in excess of the quantities ordered, the Company will not be bound to pay for the excess and such excess will be and remain at the Seller’s risk and be returnable at the Seller’s expense. In the event that the Seller does not arrange for the additional Goods to be returned within 14 days of the date of delivery, the Company shall be entitled to retain the additional Goods, at no cost to the Company; (b) so that the same represents less than 95% of the quantity ordered, the Company may reject the Goods.

6.8 Where Condition 6.7 applies, and if and only if the Company accepts the relevant delivery, a pro-rata adjustment shall be made to the invoice for the Goods.

6.9 The Company will not be deemed to have accepted the Goods until it has had 14 days to inspect them following delivery. The Company will also have the right to reject the Goods as though they had not been accepted after any latent defect in the Goods has become apparent. The Company’s rights under this Condition 6.9 are without prejudice to the Company’s rights under Condition 11.2 which are not affected by any acceptance of the Goods by the Company.

7. REMEDIES

7.1 If the Goods and/or Services are not delivered on the Delivery Date, , or do not comply with the undertakings set out in Condition 3.2 and/or 4.3, or otherwise in accordance with the Contract, then, without limiting any of its other rights or remedies, and whether or not it has accepted the Goods, the Company may exercise any one or more of the following remedies: (a) to terminate the Contract; (b) to reject the Goods (in whole or in part) and return them to the Seller at the Seller’s own risk and expense; (c) to require the Seller to repair or replace the rejected Goods, to re-perform the Services, or to provide a full refund of the price of the rejected Goods and/or Services (if paid); (d) to refuse to accept any subsequent delivery of the Goods and/or to accept any subsequent performance of the Services which the Seller attempts to make; (e) to recover from the Seller any costs incurred by the Company in obtaining substitute goods and/or services from a third party; and (f) to claim damages for any other costs, loss or expenses incurred by the Company which are in any way attributable to the Seller’s failure to carry out its obligations under the Contract.

7.2 If the Goods are not delivered on the Delivery Date the Company may, at its option, claim or deduct a sum equal to the actual costs incurred by the Company as a result of the relevant delay in the Delivery Date, which shall include, without limitation transport and labour costs. If the Company exercises its rights under this Condition 7.2, it shall not be entitled to any of the remedies set out in Condition 7.1 in respect of the Goods’ late delivery (but such remedies shall be available in respect of the Goods’ condition).

7.3 These Conditions shall apply to any replacement Goods and/or Services supplied by the Seller.

7.4 The Company’s rights and remedies under these Conditions are in addition to its rights and remedies implied by statute and common law.

8. TITLE AND RISK

8.1 Risk in and title and ownership of the Goods will pass to the Company on completion of delivery, unless the Company has paid for any Goods in advance, in such instances title in the Goods on the date payment for the same was made.

9. INTELLECTUAL PROPERTY

9.1 The Company authorises the Seller to use the Intellectual Property Rights of the Company, including without limitation the Company Materials, for the purposes only of exercising its rights and performing its obligations under the Contract. The Seller will have no other rights whatsoever in respect of the Intellectual Property Rights of the Company, and the Company Materials are the exclusive property of the Company.
9.2 The Seller grants to the Company ,or shall procure the direct grant to the Company of, a fully paid-up, worldwide, non-exclusive, royalty-free perpetual and irrevocable licence to copy and modify the Deliverables (excluding Customer Materials) for the purpose of receiving and using the Services and the Deliverables.
9.3 The Seller warrants that neither the Goods, nor their use, resale or importation, infringes any patent, copyright, registered design, design right, trade mark, trade name or other intellectual property right of any third party worldwide except to the extent that any infringements arise from any Specifications, drawings, samples or descriptions provided by the Company.
9.4 If the Seller makes or discovers any discovery, invention, secret, process or improvement pursuant to a Contract, then the Seller will make full disclosure to the Company and the said discovery, invention, process or improvement and any and all Intellectual Property Rights therein shall belong to and be the absolute property of the Company and the Seller will do all such things necessary or desirable to vest such Intellectual Property Rights in the Company absolutely.
9.5 All drawings, designs, data, documents, models, proto types, logos and other tradenames or trademarks, domain names or similar and any other materials produced by the Seller pursuant to a Contract in whatever medium held or recorded and the copyright and/or design right and/or other rights therein and thereto shall belong to the Company absolutely. The Seller hereby irrevocably and unconditionally waives any and all moral rights (if any) conferred on it by virtue of the Copyright Designs and Patents Act 1988 in any work arising from the provision of the Goods.

10. LIABILITY & INDEMNITY

10.1 The Seller will indemnify, keep indemnified and hold harmless the Company from and against all costs (including the cost of enforcement), expenses, liabilities (including any tax liability) injuries, direct, indirect loss (all of which terms include, without limitation, pure economic loss, loss of profits, loss of business, depletion of goodwill and like loss), damages, claims (including without limitation any claims made against the Company by any of its customers), demands, proceedings or legal costs (on a full indemnity basis) and judgements which the Company incurs or suffers: (a) as a consequence of a direct or indirect breach or negligent performance by the Seller or failure or delay in performance of the terms of the Contract; (b) as a result of or in connection with any claim made against the Company for actual or alleged infringement of a third party’s intellectual property rights arising out of or in connection with the supply or use of the Goods, and/or the use of the Services to the extent that the same is attributable to the acts or omissions of the Seller, its employees, agents or sub-contractors; (c) any regulatory fine or penalty arising out of or in connection with the provision of the Goods and/or performance of the Services except to the extent such fine or penalty arises as a result of the negligence, fraud, wilful misconduct or wrongful act of the Company, its affiliates or its or their respective officers, directors, partnership, shareholders, employees or agents; (d) any claim made against the Company by a third party for default, personal injury or damage to property arising out of or in connection with defects in the Goods and/or Services, to the extent that the defects in the Goods and/or Services are attributable to the acts or omissions of the Seller, its employees, agents or subcontractors.
10.2 The Seller shall hold and maintain in force during the Contract and for a period of ten years thereafter (or such period as the Company shall reasonably require from time to time) product liability and professional negligence insurance policies with an indemnity limit of £10,000,000 (or such other sum as the Company may from time to time reasonably require) to cover its liabilities to the Company under these Terms and Conditions. The Company shall be entitled to inspect such policies at any time on reasonable notice and shall be supplied with the current premium receipt from time to time on demand.
10.3 Nothing in this Agreement limits or excludes a party’s liability for: (a) death or personal injury arising out of negligence; (b) fraud, fraudulent misrepresentation, criminal acts or the tort of deceit; or (c) where such a limitation or exclusion would be contrary to law.

11. CONTAMINATION & PRODUCT RECALLS

11.1 In the event that any Goods supplied by the Seller (whether or not such Goods have been supplied to the Company) are discovered to have been contaminated whether deliberately or accidentally prior to delivery by the Seller, the Company shall be entitled, without further liability to the Seller: (a) to suspend delivery of; and/or (b) to terminate any Contract for; and/or (c) to require the Seller to collect at its own risk and expense any stocks already held by the Company of any Goods so contaminated and/or any Goods of the same description as those so contaminated and/or any other Goods supplied by the Seller the resale of which the Company, in its absolute discretion, considers is or will be commercially unviable as a result of the contamination and the Company shall be released from any obligation which has already arisen to pay for, and shall be entitled to a full refund of any sums already remitted in payment for, any such goods.
11.2 For the purpose of Condition 11.1, Goods will be deemed to be contaminated where they contain any substance or possess any quality or attribute which, in the Company’s opinion, is actually or potentially harmful to consumers or renders re-sale of the Goods commercially unviable or where a claim by any person that the goods have been interfered with becomes public knowledge.
11.3 The Company shall have sole discretion over whether and under what circumstances to: (a) notify UK or overseas regulators; (b) undertake recalls; (c) take any other steps in relation to the Goods supplied to protect the safety of consumers.
11.4 The Seller at its own expense must: (a) immediately notify the Company should the Seller take the view that there is an issue that may require any of the actions identified at Condition 11.3, or if there is any suspicion that there may be a quality or safety issue regarding any Goods; (b) cooperate with the Company in relation to any recall or other action taken to protect the safety of consumers, including by providing all relevant information; and (c) subject to Condition 11.5 below, pay the costs arising from any of the actions identified at Condition 11.3.
11.5 In the event that a recall is necessary for reasons in addition to the fault or negligence of Seller or its agents, then the Seller and the Company shall be responsible for a proportionate share of such costs, to be agreed between the parties.

12. TERMINATION

12.1 The Company may by written notice served on the Seller terminate the Contract (or any unfulfilled part thereof) immediately if the Seller: (a) is in material breach of any of the terms of the Contract and, where the breach is capable of remedy, the Seller fails to remedy such breach within 7 days’ service of a written notice from the Company, specifying the breach and requiring it to be remedied. Failure to deliver Goods on the due date in accordance with Condition 6.2 is a material breach of the terms of the Contract which is not capable of remedy; (b) the Supplier takes any step or action in connection with its entering administration, provisional liquidation or any composition or arrangement with its creditors (other than in relation to a solvent restructuring), being wound up (whether voluntarily or by order of the court, unless for the purpose of a solvent restructuring), having a receiver appointed to any of its assets or ceasing to carry on business or, if the step or action is taken in another jurisdiction, in connection with any analogous procedure in the relevant jurisdiction; (c) the Supplier takes any step or action in connection with the Supplier being made bankrupt, entering any composition or arrangement with his creditors, having a receiver appointed to any of his assets, or ceasing to carry on business [or if the step or action is taken in another jurisdiction, in connection with any analogous procedure in the relevant jurisdiction]; (d) the Supplier suspends, or threatens to suspend, or ceases or threatens to cease to carry on all or a substantial part of its business; or (e) the Supplier’s financial position deteriorates to such an extent that in the Customer’s opinion the Supplier’s capability to adequately fulfil its obligations under the Contract has been placed in jeopardy.
12.2 The termination of the Contact howsoever arising is without prejudice to the rights, duties and liabilities of either the Seller or the Company accrued prior to termination and the conditions which expressly or impliedly have effect after termination will continue to be enforceable notwithstanding termination.
12.3 The Company may terminate the Contract in whole or in part at any time before delivery with immediate effect by giving the Seller written notice, whereupon the Seller shall discontinue all work on the Contract. The Company shall pay the Seller fair and reasonable compensation for any work in progress on the Goods at the time of termination, but such compensation shall not include loss of anticipated profits or any consequential loss.
12.4 The Seller shall immediately deliver to the Company all Deliverables whether or not then complete,and return all Company Materials. If the Seller fails to do so, then the Company may enter the Seller’s premises and take possession of them. Until they have been returned or delivered, the Seller shall be solely responsible for their safe keeping and will not use them for any purpose not connected with the Contract.

13. CONFIDENTIALITY

12.1 The Seller will keep confidential any and all Confidential Information that it may acquire.
12.2 The Seller will not use the Confidential Information for any purpose other than to perform its obligations under the Contract. The Seller will ensure that its officers and employees comply with the provisions of this Condition 12.
12.3 The obligations on the Seller set out in Conditions 12.1 and 12.2 will not apply to any information which: (a) is publicly available or becomes publicly available through no act or omission of the Seller; or (b) the Seller is required to disclose by order of a court or regulatory body of competent jurisdiction.

14. GENERAL

14.1 Each right or remedy of the Company under any Contract is without prejudice to any other right or remedy of the Company under this or any other Contract.
14.2 If any condition or part of the Contract is found by any court, tribunal, administrative body or authority of competent jurisdiction to be illegal, invalid or unenforceable then that provision will, to the extent required, be severed from that Contract and will be ineffective without, as far as is possible, modifying any other provision or part of the Contract and this will not affect any other provisions of the Contract which will remain in full force and effect.
14.3 No failure or delay by the Company to exercise any right, power or remedy will operate as a waiver of it nor will any partial exercise preclude any further exercise of the same, or of some other right, power or remedy.
14.4 The Company may assign, delegate, license, hold on trust or sub-contract all or any part of its rights or obligations under the Contract.
The Contract is personal to the Seller who may not assign, delegate, license, hold on trust or sub-contract all or any of its rights or obligations under the Contract without the Company’s prior written consent.
14.5 The parties to the Contract do not intend that any of its terms will be enforceable by virtue of the Contracts (Rights of Third Parties) Act 1999 by any person not a party to it.
14.6 The Contract and the Specification contain all the terms which the Company and the Seller have agreed in relation to the Goods and supersedes any prior written or oral agreements, representations or understandings between the parties relating to such Goods. The Seller acknowledges that it has not relied upon any warranty, representation, statement or understanding made or given by or on behalf of the Company which is not set out in the Contract or Specification. Nothing in this Condition 14.9 will exclude any liability which one party would otherwise have to the other party in respect of any statements made fraudulently.

15. COMMUNICATION

15.1 Subject to the conditions relating to orders in Condition 2, any notice, demand or communication in connection with the Contract will be in writing and may be delivered by hand, first class post or facsimile, addressed to the recipient at its registered office (or such other address the recipient has notified in writing to the sender in accordance with this Condition 15, to be received by the sender not less than seven Business Days before the notice is despatched).
15.2 The notice, demand or communication will be deemed to have been duly served: (a) if delivered by hand, at the time of delivery; (b) if delivered by first class post, 48 hours after being posted (excluding days other than Business Days); provided that, where in the case of delivery by hand, such delivery occurs either after 4.00 pm on a Business Day, or on a day other than a Business Day, service will be deemed to occur at 9.00 am on the next following Business Day.
15.3 For the avoidance of doubt, where proceedings have been issued in the Courts of England and Wales, the provisions of the Civil Procedure Rules must be complied with in respect of the service of documents in connection with those proceedings.

16. FORCE MAJEURE

16.1 Neither party shall be liable or responsible to the other party, nor be deemed have breached this Agreement, for any failure or delay in performing or completing any obligation under this Agreement, when such failure or delay is caused by or results from an event that is beyond such party’s (the “Impacted Party”) reasonable control including, without limitation, the following events (the “Force Majeure Events”): (i) acts of God (but excluding normal weather conditions such as rain or snow), flood, fire, earthquake, blizzard; (ii) explosion, war, invasion, hostilities (whether or not war is declared), terrorist threats (including general threats) or acts, riot, other civil unrest; (iii) government order or action, eminent domain, condemnation of property, changes in laws or regulations; (iv) organized labor activities or disturbances such as strikes; (v) shortages of power, supplies, infrastructure, or transportation; (vi) emergencies (whether global, national, regional, or local); and (vii) pandemic, epidemic, or quarantines. The Impacted Party shall, as soon as reasonably practicable, give notice of the Force Majeure Event to the other party stating the period of time the Force Majeure Event is expected to last.

17. GOVERNING LAW & JURISDICTION

17.1 The Contract, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation, shall be governed by and construed in accordance with the law of England and Wales.
17.2 Each party irrevocably agrees that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with the Contract or its subject matter or formation.

XI. EXERCISING YOUR DATA SUBJECT RIGHTS

To exercise any of the rights described above, please submit a verifiable consumer request to us via the methods described below.

Email: privacy@rich.com
Submit a request: Rich’s Privacy Web Form
Global Headquarters
Call us: 1-877-352-0077
Write us: Rich Products Corporation
One Robert Rich Way
Buffalo, New York 14213

EEA & UK
Call us: +44 (0)330 060 5100
Write us: Rich Andover Realty Limited
Unit 5 Pioneer Road
Andover Business Park
Andover, GB SP11 8EZ

We have also appointed a Data Protection Officer (DPO) for the EEA and UK. You can contact the DPO at ukdpo@rich.com.

The verifiable consumer request must:

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

To help protect your privacy and maintain security, if you request access to, correction, or deletion of your Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Information is the subject of the request. Only you or your authorized agent may make a verifiable consumer request related to your Information. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above). You may also make a verifiable consumer request on behalf of your minor child.

XII.GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

Our Services are targeted to individuals located in the United States. As such, the Services collect Information and process and store that Information in databases located in the United States. If you are visiting the Services from a country outside the United States, you should be aware that you may transfer personally identifiable Information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Services and submitting any personally identifiable Information you consent to the transfer of such personally identifiable Information to the United States.

XIII. CHILDREN’S INFORMATION

To Rich’s knowledge, we do not collect, sell, share, or disclose Information for users under the age of sixteen (16). The Services are intended only for users over the age of sixteen (16). If we become aware that a user is under sixteen (16) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of sixteen (16).

XIV. DIFFICULTY ACCESSING OUR PRIVACY POLICY

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

XV. “DO NOT TRACK” SIGNALS

We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the sale or sharing of personal Information, or the use of sensitive personal Information.

XVI. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify or amend this Privacy Policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements, or other purposes. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes.

XX. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Information we have collected about you, please contact us at the following:

Email: privacy@rich.com
Submit a request: Rich’s Privacy Web Form

Global Headquarters
Call us: 1-877-352-0077
Write us: Rich Products Corporation
One Robert Rich Way
Buffalo, New York 14213

EEA & UK
Call us: +44 (0)330 060 5100
Write us: Rich Andover Realty Limited
Unit 5 Pioneer Road
Andover Business Park
Andover, GB SP11 8EZ

We have appointed a Data Protection Officer (DPO) for the EEA and UK. You can contact the DPO at ukdpo@rich.com.

Effective Date: September 10, 2024

RICH PRODUCTS PRIVACY POLICY

TABLE OF CONTENTS

I. INFORMATION WE COLLECT ABOUT YOU

II. COOKIES & TECHNOLOGIES USED TO COLLECT INFORMATION ABOUT YOU

III. HOW WE USE YOUR INFORMATION

IV. SHARING OR DISCLOSING YOUR INFORMATION

V. CATEGORIES OF INFORMATION SOLD

VI. LINKS TO OTHER WEBSITES

VII. INFORMATION SECURITY

VIII. DATA RETENTION

IX. YOUR CHOICES

X. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS

XI. EXERCISING YOUR DATA SUBJECT RIGHTS

XII. GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

XIII. CHILDRENS INFORMATION

XIV. DIFFICULTY ACCESSING OUR PRIVACY POLICY

XV. “DO NOT TRACK” SIGNALS

XVI. CHANGES TO THIS PRIVACY POLICY

XVII. HOW TO CONTACT US

I. INFORMATION WE COLLECT ABOUT YOU

A. Information You Provide to Us

B. Sensitive Information

C. Information We May Automatically Collect About You

D. Information We May Receive from Third Parties

II. Cookies & Technologies Used to Collect Information About You

III. HOW WE USE YOUR INFORMATION

A. Use and Purpose of Processing Your Information

IV. Sharing or Disclosing Your Information

V. Categories of Information Sold

VI. LINKS TO OTHER WEBSITES

VII. INFORMATION SECURITY

VIII. DATA RETENTION

IX. YOUR CHOICES

X. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS

A. NOTICE TO CALIFORNIA RESIDENTS

1. Your Rights under CCPA

2. Authorized Agent

3. Notice of Financial Incentive

4. Additional Information

B. NOTICE TO VIRGINIA RESIDENTS

1. Your Rights under VCDPA

2. Additional Information

C. NOTICE TO COLORADO RESIDENTS

1. Your Rights under CPA

2. Sensitive Data

3. Authorized Agent

4. Notice of Financial Incentive

D. NOTICE TO CONNECTICUT RESIDENTS

1. Your Rights under CTDPA

2. Authorized Agent

3. Additional Information

E. NOTICE TO UTAH RESIDENTS

1. Your Rights under UCPA

F. NOTICE TO TEXAS RESIDENTS

1. Your Rights Under TDPSA

2. Sensitive Data

3. Authorized Agent

G. NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND THE UK

1. Identity and Contact Details of Controller and EU Representative

2. Your Data Protection Rights

3. Lawful Basis for Processing Your Information

4. Consent to Transfer

5. Retention

6. Modern Slavery Statement

7. Terms & Conditions Of Purchase

XI. EXERCISING YOUR DATA SUBJECT RIGHTS

XII.GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

XIII. CHILDREN’S INFORMATION

XIV. DIFFICULTY ACCESSING OUR PRIVACY POLICY

XV. “DO NOT TRACK” SIGNALS

XVI. CHANGES TO THIS PRIVACY POLICY

XX. HOW TO CONTACT US

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