PRIVACY POLICY

Effective Date: 5/29/2020

Summit Naturals, Inc. dba HighKey Snacks (“HighKey,” “we,” “our,” or “us”) respects your concerns about privacy and values the relationship we have with you. This Privacy Policy describes the types of information we collect about you if you visit our website(s) (www.HighKey.com), or engage with us online, in-person, or via social media, and how we use the information, including with whom we share it, and your choices regarding our use of the information. We also describe how you can contact us with questions and requests pertaining to your privacy. This Privacy Policy does not address data collection by any retail partners.

 

INFORMATION WE COLLECT

We may obtain information, including personal information, about you from various sources. We may collect this information when you provide it on our website, via our social media pages, at one of our events, or from our retail partners.  When you visit www.HighKey.com, our social media accounts, or other promotional web pages created and maintained by us, we may also collect certain information about the device you are using by automated means, including using technologies such as cookies, web server logs and web beacons. 

INFORMATION YOU PROVIDE

You may choose to provide information to us in a number of ways, such as when you participate in an offer or promotion, when you make a purchase on our site, or via our social media pages.

The types of personal information you may provide to us includes:

  • Contact information (such as name, postal address, email address, mobile or other phone number, and mobile service provider)
  • Age and date of birth
  • Gender
  • Username and password
  • Payment information (such as your payment card number, expiration date, delivery address and billing address)
  • Purchase history
  • Product preferences
  • Your physical characteristics and diet concerns
  • Contact information for friends or other people you would like us to contact
  • Content you provide (such as photographs, videos, reviews, articles, survey responses and comments)
  • Information provided to us through social media networks when you visit our social media pages (such as your name, profile picture, likes, location, friend list and other information described on the social media network)

 

HOW WE USE THE INFORMATION

We may use the information you provide to:

  • Send you promotional materials or other communications that we think will interest you
  • Provide services to you
  • Process your payment card and/or gift card transactions
  • Create and manage your online account, including access to your online purchase history
  • Assist with product selection and replenishment
  • Respond to your inquiries
  • Tailor ads displayed to you on our site and elsewhere to your interests and history with us
  • Communicate with you about, and administer your participation in, special events, contests, sweepstakes, programs, surveys and other offers
  • Operate and communicate with you about our social network pages or mobile applications
  • Operate, evaluate and improve our business (including developing new products and services; managing our communications; analyzing our products; performing data analytics; and performing accounting, auditing and other internal functions)
  • Comply with applicable legal requirements, relevant industry standards and our policies

We also may use the information in other ways for which we provide specific notice at the time of collection.

 

INFORMATION WE COLLECT BY AUTOMATED MEANS

When you visit our website(s), view or click on our online advertisements (including our advertisements on third party websites), or visit our social media pages, we also collect certain information about your usage or device by automated means via third-party technologies such as cookies, web server logs and web beacons. For example, when you visit our website, we may collect your IP address, your unique device identifier (or other device identifier) and/or geolocation data in order to offer you certain features or functionalities. As set forth in more detail below, we may also collect information about your usage and browsing habits using various web-based technologies, including cookies and web beacons.

 

TECHNOLOGIES WE USE COOKIES, WEB SERVER LOGS AND WEB BEACONS

Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.

In conjunction with obtaining information through cookies, our web servers may log details such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. The web server logs also may record information such as the address of the web page that linked you to our site and the IP address of the device you use to connect to the Internet.

To control which web servers collect this information, we may place tags on our web pages called “web beacons.” These are computer instructions that link web pages to particular web servers and their cookies.

 

THIRD PARTY WEB ANALYTICS SERVICES

We may use third party web analytics services on this site, or our social network pages, such as those of Criteo, Quantcast and/or Google Analytics. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the site. 

The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the website. You may deactivate the ability of these analytics services to analyze your browsing activities on this site. These providers of third-party web analytics services have their own terms and conditions and privacy policies. Highkey does not control what these providers do with information they collect.

 

TARGETED ADVERTISING

We also may contract with third-party advertising networks that collect IP addresses and other information through the use of cookies, web server logs and web beacons on our websites and emails; on third-party websites and emails; and on our advertising placed on third-party websites. They use this information to provide advertisements about products and services tailored to your interests (including for companies not affiliated with us). You may see these advertisements on our websites and other websites. This process also helps us manage and track the effectiveness of our marketing efforts. To learn more about advertising networks and to opt out of interest-based advertising, visit the Digital Advertising Alliance at www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/choices.

 

COOKIES
The cookies and web technologies we use on our website are listed below, along with a link to additional information about it.

Cookie Provider

Cookie type/purpose

Info (Link to provider website)

Criteo

Marketing & Analytics

https://www.criteo.com/

Refersion

Marketing & Analytics

https://www.refersion.com/

Yahoo DOT Tag

Marketing & Analytics

https://www.yahoo.com/

Yotpo

Marketing & Analytics

https://www.yotpo.com/

Google/Doubleclick

Marketing & Analytics

https://www.google.com/

Mixpanel

Marketing & Analytics

https://mixpanel.com/

Metrilo

Marketing & Analytics

https://www.metrilo.com/

MyFonts Counter

Marketing & Analytics

https://www.myfonts.com/

Quantcast

Marketing & Analytics

https://www.quantcast.com/

Recharge

Marketing & Analytics

https://rechargepayments.com/

LinkedIn

Marketing & Analytics

https://www.linkedin.com/legal/cookie-policy

Microsoft (Bing)

Marketing & Analytics

https://privacy.microsoft.com/en-us/privacystatement

Hulkapps

Marketing & Analytics; Functionality; Performance

https://www.hulkapps.com/pages/privacy-policy

Shopify

Marketing & Analytics; Functionality; Essential; Performance

https://www.shopify.com/legal/cookies

Outbrain/Quora

Marketing & Analytics

https://outbrain.pactsafe.io/versions/58b48d50b8ffc11fa2ea0828.pdf; https://www.quora.com/about/cookies

Visual Website Optimizer

Marketing & Analytics

https://vwo.com/opt-out/

 

DO NOT TRACK REQUESTS

Please note that our website does not respond to “Do Not Track” requests. More information on “Do Not Track” requests is available here: https://allaboutdnt.com/

 

HOW WE USE THE INFORMATION COLLECTED BY AUTOMATED MEANS
We may use the information collected through automated means on this site for market research, data analytics and system administration purposes, such as to determine whether you’ve visited us before or are new to the site, to tailor ads displayed to you on our site and elsewhere, and for compliance with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our Terms of Service. We also may use the information in other ways for which specific notice is provided at the time of collection.

 

SMS/MMS MOBILE MESSAGING MARKETING PROGRAM (“PROGRAM”)

We will only use information you provide through the Program to transmit your mobile messages and respond to you, if necessary. This includes, but is not limited to, sharing information with platform providers, phone companies, and other vendors who assist us in the delivery of mobile messages. WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR CUSTOMER INFORMATION COLLECTED THROUGH THE PROGRAM TO ANY THIRD PARTY. Nonetheless, we reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property. When you complete forms online or otherwise provide us information in connection with the Program, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in our sole discretion, we believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Program for an ulterior purpose, we may refuse you access to the Program and pursue any appropriate legal remedies.

 

By providing your phone number, you are expressly consenting and opting in to receiving automated text messages from HighKey, including recurring messages. We may text you about your shopping cart, orders, your experience with our products or our website, or to respond to your inquiries. We may also text you about sales, promotions, or other products that we think you may be interested in. By providing your phone number, you are expressly authorizing us to send you these messages to your mobile device. Please note that your use of the site and your ability to make purchases from the site is not conditioned upon your consent to receive messages from us. Message frequency varies and message and data rates may apply and are your responsibility.

 

You may revoke your consent to receive text and/or multimedia messages to your phone at any time by contacting us at info@HighKey.com or by replying STOP to any text message you receive from us.

You may also contact us at the below address regarding how we use your information in connection with the Program:

HighKey Snacks

5160 Industrial Place #106

Ferndale, WA 98248

info@HighKey.com

 

INFORMATION WE SHARE

We do not rent lists, or sell, or otherwise disclose personal information we collect about you, except as described here. We may share your personal information with third party service providers who perform services on our behalf based on our instructions and with your consent, which is given by your continued use of our website or engagement on social media

We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf, with your consent, or to comply with legal requirements.

The personal information shared by you helps us to make our products and services better for you by helping us:

  • Fulfill your orders for products and services.
  • Notify you about new products, services, features, updates etc.
  • Provide you customer service such as answering your questions, responding to your inquiries, or addressing any issues that arise out of your use of our products and services.
  • Provide a personalized experience while using our site.
  • Deliver the type of products and services you are interested in.
  • Alert you about upgrades, special offers, events, promotions etc.

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

 

YOUR RIGHTS AND CHOICES

We offer you certain choices in connection with the personal information we collect from you, such as how we use the information and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists, or submit a request, please contact us in the manner specified below.

 

EMAIL OPT-OUT

You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us, managing preferences here or by contacting us as indicated below. 

Although you may opt out of HighKey Snacks marketing emails, operational emails will still be sent to you. Examples of these include, but are not limited to, a redemption confirmation email, a profile update email, or other communications that relate to your account.

 

REVIEWING, UPDATING AND MODIFYING PERSONAL INFORMATION

Subject to applicable law, you may have the right to request access to and receive details about the personal information we maintain about you, update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate. The right to access personal information may be limited in some circumstances by local law requirements. We may take reasonable steps to verify your identity before granting access or making corrections. You may request to review, change or delete your personal information by sending an email to info@HighKey.com

 

HighKey Snacks

5160 Industrial Place #106

Ferndale, WA 98248

 

TRANSFER OF PERSONAL INFORMATION TO OTHER JURISDICTIONS

HighKey Snacks is located in the United States, and if you are located outside of the United States, your personal information may be transferred and proceed within the United States as part of our normal business operations. Data protection laws vary from country to country, and may be different from the country from where you access the HighKey Snacks website. By using our website or services, you consent to the transfer and processing of personal information by HighKey Snacks and our third party service providers who perform services on our behalf based on our instructions.

 

CHILDREN’S PRIVACY

This site is not directed at children under the age of thirteen and we do not knowingly collect personal information from children under the age of thirteen. If we become aware that we have inadvertently received personal information from a visitor under the age of thirteen on the site, we will delete the information from our records. If you are between 13 and 16 years old, you are required to get consent from your parent(s) or guardian(s) before accessing the site.

You may request to review, change or delete your personal information or that of your minor child.

To make such a request, please contact us at the following address:

HighKey Snacks

5160 Industrial Place #106

Ferndale, WA 98248

info@HighKey.com

 

HOW WE PROTECT PERSONAL INFORMATION

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no security system is perfect and we cannot promise that information about you will remain secure in all circumstances, including the security of your data during transmission to us or the security of data on your mobile device.

 

LINKS TO OTHER WEBSITES

Our website may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites.

 

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on www.HighKey.com. If we make material changes to this policy, we will notify you that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. Your continued use of the website after being notified of, or becoming aware of, a chance in this policy, is your affirmation that you have read and understood this policy, agree to it, and agree to be bound by it.

 

CALIFORNIA USERS AND THE CALIFORNIA CONSUMER PRIVACY ACT

 

The California Consumer Privacy Act (“CCPA”) provides California residents with the additional rights listed below, subject to certain exceptions. This section applies only to those California residents to whom the CCPA applies (“California Resident” or “You”) and does not apply to any Personal Information, as defined in the CCPA (“PI”), that is excepted from the CCPA. All capitalized words in this section have the definitions given to them in the CCPA, as amended, unless noted.

 

California Residents have the right to:

 

  1. Request disclosure of our data Collection and sales practices in connection with you, including the categories of PI we have collected, the source of that PI, our use of that PI and, if the disclosed or Sold to third parties, the categories of PI disclosed or Sold to third parties and the categories of third parties to whom such PI was disclosed or Sold;
  2. Request a copy of the specific PI collected about you during the 12 months before your request made under the previous paragraph;
  3. Have such PI deleted (with exceptions);
  4. Request that your PI not be Sold to third parties, if applicable (Right to Opt Out); and
  5. Not be discriminated against because you exercised any of these rights.

 

Right to Request and Right to Know. You have the right to know and what PI we have Collected about you over the past 12 months, and the right to request that PI, including:

  • The categories of PI we have collected about you;
  • The categories of sources from which the PI is collected;
  • The Business purpose or Commercial purpose for Collection of your PI;
  • The categories of Third parties with whom we have shared your PI; and
  • The specific PI we have Collected about you.

 

You may exercise the Right to Request no more than twice a year.

 

Categories of Information We Collect.

 

 

Category

Source

1

Identifiers (such as contact information, government IDs, cookies, etc.)

A, B, C

2

Information protected against security breaches (such as your name and financial account, driver’s license, social security number, health/medical information subject to HIPAA)

[NOT COLLECTED]

3

Protected classification information (like race, gender, ethnicity, etc.)

A (Gender)

4

Commercial information

[NOT COLLECTED]

5

Internet/electronic activity

A, B, C

6

Geolocation

C (based on IP address)

7

Audio/video data

[NOT COLLECTED]

8

Professional or employment related information

[NOT COLLECTED]

9

Education information

[NOT COLLECTED]

10

Biometrics

[NOT COLLECTED]

11

Inferences from the foregoing

A, B, C

 

Key to Sources:

 

Source:

A

Individual submitting the information

B

Third party from whom we receive the information

C

Observing activities and recording the information (i.e., through cookies)

 

We collect Personal Information for one or more of the following commercial and business purposes, in addition to what is otherwise disclosed in this Privacy Policy:

 

  • Providing you with our products and services;
  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business;
  • Marketing and advertising our products and services to you, including based on your advertising preferences;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Undertaking internal research for technological development and demonstration; and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

 

If we collect any additional PI for any other purpose, we will notify you of that purpose at the time we collect the PI for that purpose.

 

If we disclose PI for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that PI confidential and not use it for any purpose except performing the contract. We share PI with the following categories of Third parties: payment processors and shipment vendors, business consultants, select marketing and advertising providers, and other service providers. We do not sell PI.

 

Right to Opt Out. We do not Sell PI. If we do engage in an activity determined to be a Sale of your PI, you will have the right to direct us to not Sell your PI. You will be able to do so by clicking on the “Do Not Sell My Information Link”  that will be found at the bottom footer of our sites. Since we do not sell PI the form is not available at this time.

 

Right to Delete. You have the right to request that we delete the PI we have Collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the PI is necessary for us or a Third party to do any of the following:

  • Complete your transaction;
  • Provide you a good or service;
  • Perform a contract between us and you;
  • Protect your security and prosecute those responsible for breaching it;
  • Fix our system in the case of a bug;
  • Protect the free speech rights of you or other users;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

 

Other Rights. You can request certain information about our disclosure of PI to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.

If you are a California Resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your PI to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to info@HighKey.com. Pursuant to California Civil Code Section 1798.83(c)(2), we do not share your PI with third parties’ direct marketing use without your consent.

 

Exercising Your California Privacy Rights. To request access to or deletion of your PI, or to exercise any other data rights under California law, please contact us via email at info@HighKey.com to exercise your California rights. Please include your full name, email address, and other identifying information such that we will be able to verify your identity, along with why you are writing, so that we can properly process your request. We are only able to handle your request if you provide the requested information needed to verify your identity.

 

Before we take any action on any request exercising a CCPA right, we must reasonably verify your identity. If we attempt to, but cannot do so, we will not be obligated to you under the CCPA. We will reach out to you by the method of communication through which you reached out to us, and let know that we are unable to verify your identity.

 

Any subsequent interaction with the Site after a request for deletion, or deletion, of PI will require new requests for action on your data.

 

Response Timing and Format. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.  

 

EUROPEAN USERS AND THE GDPR

 

This section of the Privacy Policy applies only to those who are a “data subject” under the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), and the words and phrases have the meanings attributed to them by the GDPR. The disclosures made throughout this policy apply to your personally identifiable data, and, if you are a data subject, the following also apply to you:

  1. You have the following rights:
  2. Right of access, rectification, erasure and restriction of processing: you may obtain access to your personal information stored by us by contacting us. If your personal information is inaccurate or incomplete, you may obtain the rectification of such personal information by contacting us. You may also obtain the erasure or restriction of processing of your personal information in situations where no legitimate business purpose exists or the further storage is unnecessary under statutory storage obligations by contacting us with such a request.
  3. Right to data portability: you may receive the personal information about you that you have provided to us in a structured, commonly used and machine-readable format or in another form or format compliant with the GDPR. To exercise this right, contact us.
  4. Right to object: you may object, on grounds relating to your particular situation, to the processing of your personal information. To exercise this right, you must contact us as provided herein. To the extent your personal information is processed for reasons other than direct marketing, you understand and agree that we have compelling legitimate reasons for information processing, such as providing access to our Website, maintaining our systems, and fulfilling orders. You may use ad-blocking software to limit information capture and usage, however, our website does not respond to Do Not Track requests from browsers. You may also contact us with questions about this policy or to make a removal request. Making a request does not guarantee that the request will be honored.

 

  1. Right to withdraw your consent: If you have given your consent to the collection or processing of your personal information, you may withdraw your consent without affecting the lawfulness of processing based on consent before its withdrawal by contacting us in writing.
  2. We currently store your personal information in the United States, but your personal information may be transferred stored, or processed in a location outside of the United States.
  3. If you make a request under sections (A) – (E), above, we have 30 days to respond to you. To exercise any of these rights, please contact us.
  4. The legal basis for processing your personal information is:
  5. You have given us consent by agreeing to abide by our Terms of Service, which is a binding contract, and continuing to access the website or any services we provide;
  6. You intend to make, or have made, a purchase on our site or via one of our partners;
  • Processing is necessary in order for us to maintain the normal operation of the website or our services
  1. Processing is necessary in order for us to comply with legal obligations.

 

  1. Data Retention: We will maintain personally identifiable data for the period of time necessary to fulfil the purpose for which it is obtained, unless a longer retention time is required by law.

 

Our corporate address is:

HighKey Snacks

Attn: Data Privacy

5160 Industrial Place #106

Ferndale, WA 98248

USA

 

Email: Info@highkeysnacks.com

 

You have the right to reach out to the appropriate Supervising Authority in your jurisdiction with your GDPR complaints.

 

HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at info@HighKey.com or by mail to:

 

HighKey Snacks

5160 Industrial Place #106

Ferndale, WA 98248

USA


If we need, or are required, to contact you concerning any event that involves your personal information we may do so by telephone or email.