Privacy Policy – Cut+Dry

Effective Date: January 20, 2026

This Privacy Policy (this “Policy”) describes the privacy practices of Cut and Dry Inc. (“Cut+Dry”, “we”, or “us”) with respect to personal information collected when users use, access or otherwise interact with cutanddry.com (the “B2B Platform”) and any related web sites (the “Sites”) and any services, mobile applications, products and marketing activities of Cut+Dry (collectively, including the Sites, the “Services”) that reference this Policy and how we use and share such information. By using the Services (including the Sites) you consent to the terms of this Policy.

We may change this Policy from time to time. If changes are made, notification will happen by posting the updated policy to the Sites and revising the “Updated” date. The most current version of this Policy will be effective at the time it is posted. By continuing to access or use the Sites or Services after those changes become effective, you agree to be bound by the revised Policy.

BY ACCESSING ANY OF THE SERVICES YOU AGREE TO BE BOUND TO ALL THE TERMS OF THIS POLICY.

This Policy covers the following areas:

I. Information We Collect
II. How We Use Your Information
III. How We Share Your Information
IV. Cookies and Other Tracking Technologies
V. Data Security
VI. Data Retention
VII. Children
VIII. Third Parties We Don’t Own or Control
IX. Your Privacy Rights
X. Region Specific Disclosures
XI. How to Contact Us
XII. Amendments

I. Information We Collect

Cut+Dry collects personal information from users in connection with the Site and Services. Users include visitors to the Sites and restaurant or retail business customers (“Restaurants”) who use the B2B Platform to view or place an order for products made available by food service distributor and manufacturer entities (“Suppliers”), and the subset of Suppliers who use the Services to market and/or sell products wholesale to Restaurants or other end-customers through the B2B Platform (“Partner Suppliers” and together with Restaurants, “Subscribers”). Subscribers include applicable Subscriber’s employees, contractors and agents who interact with the Services on behalf of the Subscriber (“Subscriber Agents”).

We collect your Personal Data in a number of ways and for various purposes. “Personal Data” means information that relates to you and identifies you personally, either alone or in combination with other information available to us. Examples of Personal Data are a name, an online identifier, a contact address, billing information, social media reviews and ratings, and precise Location Data (defined below). The information and types of Personal Data we collect depend on the manner and context of your interaction with us.

Restaurant users should note that Suppliers are independent third parties that maintain their own business practices and policies outside of their relationship with Cut+Dry. As a result, unless provided otherwise in this Policy, we are not responsible for the privacy policies or data practices of Suppliers, who may maintain separate policies and practices.

Restaurants and Partner Suppliers are responsible for complying with all applicable laws and regulations concerning the Personal Data of their Subscriber Agents. Restaurants and Partner Suppliers are responsible for complying with applicable laws and regulations in connection with their use of the Services, including, without limitation, those requiring notice, disclosure and/or consent in connection with the collection, transfer and processing of personal information. Restaurants and Partner Suppliers are responsible for addressing any privacy requests from their Subscriber Agents. If you are a Subscriber Agent and you have a privacy question or request, please review the Subscriber’s privacy policy and contact the Subscriber directly.

When you use our Site or Services, Personal Data may be collected as follows:

We may ask for and collect or otherwise receive Personal Data such as your name, address, phone number, email address, date of birth, gender, age, personal interests, location (e.g., city or country), commercial information such as credit card information and other similar details directly from you when you sign up for our Services, register an account with us, or when you access or utilize one or more of our Services. As part of an application process and agreement to provide the Services to Subscribers as well as updates during the course of the parties’ business relationship, we may collect Personal Data such as tax identification number, national identification number (e.g. Social Security number or passport number), drivers’ license details, banking and payment card information, and other personal information about the individual(s) executing the application and agreement, beneficial owners of the Subscriber entity, and employees of Subscriber.

When interacting with our Services, data may be automatically collected by the technology platforms providing the experiences, including without limitation information about the Sites and Services that you visit and how you use them and any GPS-based, Wi-Fi-based, or cell-based location information (“Location Data”), and any other identifier that permits direct identifying, locating, or contacting of the device or user. Your web browser or mobile device may share certain data with Cut+Dry as those devices interact with Cut+Dry Sites or Services. This data includes: Device IDs, network access, storage information and battery information as well as cookies, IP addresses, referrer headers, data identifying your web browser and version, the date and time of the visit, the path you took through the Sites and Services and how long you remained on our Sites or Services, and web beacons and tags. Location Data may also include the presence of the device, its signal strength and mobile network information, its manufacturer (Apple, Samsung, etc.) and model, and information about the device’s interaction with the Services or business services. The information we collect automatically may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.
If you correspond with us we collect records about your correspondence (including e-mail addresses and telephone recordings).

When you carry out any transactions through the Services (such as product orders), we collect purchase and browsing data, such as commercial information regarding a purchase (payment account information, payment amounts and methods, billing and shipping information, and other transaction information) and order history. We may associate purchase and browsing information to an account you have registered with us and combine it with information relating to all interactions with us.
To the extent you engage with us via a social media account or connect an account managed by third parties such as social media sites (e.g., Facebook) with a Cut+Dry account, you authorize Cut+Dry to have access to information related to that account (as permitted by the terms of service of your account with that social media site) and agree that Cut+Dry may collect, store and use such information in accordance with this Policy.
If you participate in or utilize, as applicable, contests, sweepstakes, loyalty programs, surveys, discounts, or promotional sales (“Promotions”) being offered by Cut+Dry, we may collect contact, demographic and eligibility information or other Personal Data. Promotions may also be run by a Cut+Dry service provider or co-branded with one of our business partners. In such instances, Personal Data may be collected directly by and/or shared with Cut+Dry, the service provider and/or business partner via print, website, mobile applications or other means.
We collect Personal Data relating to your interactions with advertising on the Site and Services or Cut+Dry online communities. We may collect your Personal Data when you click on advertisements, submit content, make reviews, or contribute to message boards, comment fields, blogs, and other media forums sponsored by or affiliated with Cut+Dry.
We collect information when users submit comments, ratings, and other content. We may also collect certain information metadata associated with your content (e.g., location, date/ time stamp, device type).
We may also collect information about you from third party sources, including but not limited to third-party verification services, banks, credit bureaus, mailing list providers, and publicly available sources (for the purposes among other things of supplementing the information provided by a Restaurant or Supplier and meeting certain underwriting and legal obligations) as well as personal information collected by way of a referral for use of the Services from a Restaurant or Supplier or business partner.

Personal Data we collect may be stored and processed in the United States or any other country in which Cut+Dry or its affiliates, subsidiaries, agents, or third party service providers maintain facilities and/or infrastructure,

II. How We Use Your Information

We use the information we collect to:

Provide, maintain and support the Sites and Services, such as providing information on products and services, facilitate payments, processing orders and providing status updates, enabling third parties to fulfill products or services that you have ordered, process transactions and payments through the Services, verifying your identity, troubleshooting support issues, answering customer service requests, and facilitating use of our Site or Services.
Register or manage your account and to fulfill benefits that are associated with your use of our Sites and Services or account.
Customize experiences on our Services and gain insights into our customers and communities. We use Personal Data to present products and content tailored to you, your interests and location. We also use Personal Data to better understand our customers and other individuals who access our Sites and Services which helps us develop more interesting and relevant products and services and to improve our Sites and Services.
Promote Cut+Dry’s business through advertising and marketing activities to you and others. We may use Personal Data in connection with advertising and online and offline marketing campaigns, to provide you with information on the products and services that we think are most relevant to or appropriate for you and to track the success of our marketing activities.
Use information collected from you in connection with a job application or inquiry (such as resume) for the purpose of employment consideration, availability or otherwise.
Use your information to respond to requests for support, online services, product information or to any other interaction you initiate. We may send you notifications pertaining to the performance of the Sites or Services, changes to the Sites or Services, updates to your account (including expiration and renewal notices), revisions of our Terms of Use or this Privacy Policy or formal communications relating to products or Services you have purchased.

In connection with Promotions we may use Personal Data to verify identity, communicate with you about the Promotion or about other offers, conduct market research, and ask you questions relating to the Promotion. If you participate in questions and surveys regarding the Promotion we may share your responses with business partners for their own market research and communication purposes. To opt-out of this kind of collection and sharing, you can decline to answer these kinds of questions or decline to participate in the challenge or survey altogether.

Improve our Site and Services and other Cut+Dry products or services, or to make the Sites and Services easier to use by, for example, eliminating the need for you to repeatedly enter the same information, or customizing our Site or Services (or other sites or services) to your particular preference or interests.

Manage our business and for internal operational purposes, including the analysis of trends and statistics and usage and performance of the Sites and Services, engaging in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Cut+Dry, sales, supply chain and financial analysis purposes, and enforcing our rights and complying with obligations arising from any contracts entered into between you and us, including for billing and collection.
Comply with applicable law, monitor and report compliance issues, protect the integrity of our Services, employees and users, to identify and prevent error, negligence and fraud, to perform our credit underwriting, anti-money laundering and other compliance obligations in order to determine whether to approve the application and provide a Restaurant or Supplier entity with the Services, to audit compliance with and enforce our agreements, and to resolve disputes.
We may combine Personal Data with information we receive from joint marketing partners, public databases, publicly available pages on social media platforms and other third parties, to give us better consumer insight into your needs, help us tailor our communications with you, deliver marketing messages to you and improve our business. For example, we may obtain updated email address information from email-change-of-address vendors or purchase third-party marketing data and address information and add it to our database to send you offline marketing materials, better direct our advertising and provide pertinent offers we think you are more likely to be interested in.
Create or develop analytics to support our business and that of Restaurants and Suppliers, conducting research (including the development of new products), for evaluation and improvement of the effectiveness of our Services, where consistent with applicable law for development, training, and deployment of algorithms and AI models to enhance, personalize, and deliver our Services, and generating insights that help improve the experience for both Suppliers and Restaurants.
For any other purpose with your consent.

III. How We Share Your Information

Cut+Dry may share Personal Data as part of providing the Services and for the purposes described within this Policy. This includes sharing Personal Data in the following circumstances:

Cut+Dry Affiliates. Cut+Dry may share information it collects with its direct and indirect parent and subsidiary companies and other affiliates. Those affiliates may use this information to improve and promote their businesses and services and offer you products and services that may of interest to you and for any other purposes outlined above.

Platform Suppliers. Third-party sellers offer products for sale through the B2B Platform, and we will share your Personal Data with such suppliers when you use the B2B Platform.

Service Providers and Partners. Cut+Dry may (a) connect you with, and coordinate the provision of services and products to you through, third party service providers and (b) partner with third parties in order to promote, support, enable or expand Cut+Dry’s business and products and services or enable those third parties to deliver content or advertise the products and services of Cut+Dry. Such service providers and partners include institutions and payments processors, government entities, IT cloud and hosting providers and shipping companies or postal services involved in fulfillment. We may share Personal Data with those service providers and partners and they may have access to or process your Personal Data. For example, Cut+Dry may use third-party providers to assist us with delivering, marketing and advertising products and services to you, processing payments and completing orders, and delivering customer service and support. In addition, with your knowledge and consent, our Services may gather and transfer information from other applications, functions and tools within your mobile device.

Joint Marketing and Interest Based Advertising. From time to time Cut+Dry may establish joint marketing relationships with other persons or entities whom we believe trustworthy and have privacy practices that are consistent with ours. In such cases and where permitted by applicable law we may exchange, share and/or cross-reference information, including information about you that will enable such persons or entities to contact you regarding products and services that may be of interest to you. Without limiting the generality of the foregoing, Cut+Dry may work with third party ad networks, ad exchanges, channel partners, measurement services and others (“3rd Party Advertisers”) to display more relevant advertising on our Services, and to manage our advertising on third party sites, mobile apps and online services. In order to display more relevant ads on our behalf and others, these 3rd Party Advertisers may use cookies, pixels tags, and other tools to collect browsing and activity information on our Services, on third-party sites and across different devices, which may be linked with certain offline data they may also collect IP address, device ID, cookie and advertising IDs, and other identifiers. These 3rd Party Advertisers may use this information to provide you more relevant ads and content and to evaluate the success of such ads and content. As a result, Cut+Dry ads may be displayed to you on a search results page or on third party sites.

You may also control how Facebook and other 3rd Party Advertisers display certain ads to you, as explained further in their respective privacy policies and ad preferences pages. You can also obtain more information about targeted advertising, and how to opt-out of receiving targeted ads from many third-party ad networks (including Facebook and Google) by visiting www.aboutads.info/choices (Digital Advertising Alliance).

Aggregate and De-Identified Information. We may share Personal Data in aggregated or de-identified formats, such as the usage and demographic and registration information described above or information created from Personal Data by removing direct personal identifiers, to third parties for any purpose to the extent not prohibited by law. For example, we may disclose the number of users that have been exposed to, or clicked on, advertising banners. This Policy does not limit our use or disclosure of any aggregate or de-identified information created from Personal Data in any way, and we reserve the right to use, disclose, and sell de-identified information (including de-identified information combined with non-scrubbed information that is not your personally identifiable information) to our partners, advertisers, Cut+Dry users, and other third parties at our discretion to the extent permitted by law. “De-identified” means Cut+Dry has taken reasonable precautions to protect data de-identified from you from being re-identified to you.

Business Transfers. Cut+Dry may share Personal Data with third parties in connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business. In the event Cut+Dry sells certain of its assets or goes through a structural change, such as a merger, acquisition by another company, bankruptcy, insolvency, or dissolution, Personal Data may be transferred to a third party as part of such event and thereby become subject to the privacy practices of that third party, which may materially different than those of Cut+Dry.

Disclosure through the Site or Services. Consistent with the purpose of the Site and Services, we may disclose information you provide to us to other users of the Site or Services. Accordingly, we may share information about you with people you are connected to through the Site or Services (e.g. your employees, employers, and co-workers) for the purpose of facilitating the Services.

Disclosure for Other Reasons. We may disclose Personal Data to third parties if we determine in good faith that such disclosure is necessary to enforce or apply Cut+Dry’s terms of service or other applicable agreements or policies, comply with applicable law, regulation, governmental request or legal process, protect the security or integrity of the Services, investigate, detect and prevent fraud and security breaches, or protect the rights, reputation, or property of Cut+Dry or those of our customers, affiliates, or the public. Further, we may share your Personal Data at your express direction.

Cookies and Other Tracking Technologies

Types of Technologies. Cut+Dry, its affiliates and our partners may use cookies(small data files placed on a device’s hard drive or memory),embedded scripts and other tracking technologies such as pixels, web beacons, and tags, session replay tools, screen capture technologies, embedded scripts and SDKs. These may be first party tracking technologies (placed by Cut+Dry), and third-party tracking technologies, which are placed by third party vendors or partners of Cut+Dry. For example, in the course of serving advertisements to the Sites and Services, our third-party advertisers may place or recognize a unique cookie on browsers. To the extent we use session replay technology, we may collect on a real-time basis information on how you use and navigate our Sites or Services.

In addition, some of Cut+Dry Sites and Services may contain web beacons (objects embedded in a web page or email used to check if a user has accessed content) which inter alia allows us to count how many persons read our messages and develop statistical information about the activities and features that most interest our users in order to provide more personalized content.

Some of the tracking technologies we use may last solely for your browsing session and are deleted when you close your browser, while others are persistent and stored after you close your browser.

Please note that if you view a web page created by a third party or use an application created by a third party, those third parties may use their own tracking technologies that are not subject to Cut+Dry’s control or this Policy. Cut+Dry does not respond to “do not track” browser signals or other mechanisms that provide consumers with choice regarding the collection of tracking information and allow third parties operating on the Services to collect personally identifiable information about and/or track your behavior on the Services and across websites

The tracking technologies we generally deploy fall into one of the following categories:

Strictly Necessary or Essential. These tracking technologies are necessary for the operation of the Site and Services and cannot be disabled within our systems. They include, session and load-balancing cookies required to ensure proper page functionality, security and anti-fraud tokens, and basic preference cookies necessary to remember applicable cookie consent choices. Such technologies are typically deployed only in response to actions you take when interacting with the Services, including browsing, requesting services, configuring privacy settings, logging into accounts, or submitting forms. Although you may configure your browser to block or provide alerts regarding these technologies, doing so may impair the functionality or availability of certain features of the Services.
These tracking technologies permit the Services to deliver enhanced functionality and personalization, and to evaluate and optimize Service performance through A/B testing, heatmapping, and UX diagnostics. Such technologies may be deployed directly by us or by third-party service providers whose services are added into our pages. If you choose not to permit these tracking technologies, some or all of the associated features and services may not operate as intended.
Performance or Analytics. These tracking technologies enable us to measure visits, traffic sources, navigation paths, conversions, and campaign attribution in order to evaluate and enhance the performance of the Services. They assist us in identifying which pages are most and least frequently accessed and in understanding how users navigate through the Services. If you do not permit these tracking technologies, we will not be able to know when you visited the Services or monitor and assess performance. Analytics data, including information relating to online identifiers such as cookie identifiers or derived geolocation data, may be collected through, or shared with, Cut+Dry’s analytics service providers, including Google Analytics. For additional information regarding Google Analytics, please visit https://policies.google.com/technologies/partner-sites. Information on how to opt out of Google Analytics is available at https://tools.google.com/dlpage/gaoptout.
Social Media. These tracking technologies are deployed by various social media Cut+Dry has integrated into the Services to facilitate the sharing of our content with your contacts and networks. Such technologies may track your browser activity across other websites and compile a profile of your interests, which may influence the content and advertisements you encounter on other sites. If you do not permit these tracking technologies, these sharing tools may be unavailable.
Marketing or Advertising. Marketing tracking technologies may be deployed through our Services by our advertising partners (including, Google Ads/DoubleClick, Meta/Instagram, and LinkedIn). These technologies may be used by Cut+Dry and such third parties to develop a profile of your interests, for audience comparison and cross-site attribution, and to deliver advertisements tailored to you on other sites. By not permitting these technologies, you will experience less targeted advertising.

Types of Data. Categories of information that may be collected through tracking technologies include IP Address, location, Cookie ID, Device ID, Operating system, device type, device settings, browser type, browser history, search history, pages viewed, general geolocation, other unique identifier, and other data about your interaction with the Site and Services. The tracking technologies may capture details about how you engage with the Services, including scrolling and cursor movements, scrolls, gestures, clicks, taps, and keyboard entries.

Use of Data. We use tracking technologies for a number of reasons, such as to identify the status of the user, customize the Sites and Services, mitigate risks and the potential for fraud, to see which features are most popular, counting visitors to a page, improving our users’ experience, advertising and content personalization on the Site and Services and those of third parties, tracking activity over time and across properties to develop a profile of your interests and advertise to you based on those interests (“interest-based advertising”), providing you with offers and online content that may be of interest to you, improving our Site and Services, keeping our services secure and generally providing you with a better experience.

We may disclose data collected through tracking technologies to Suppliers, analytics providers, security providers, advertising networks, social media companies and other technology and business partners.

We may combine information collected through tracking technologies with other information we obtain about you, which may include data we obtain from external parties. If you view a web page created by a third party or use an application created by a third party, those third parties may use their own tracking technologies that are not subject to Cut+Dry’s control or this Policy. For instance, we use Google Analytics to collect and process certain analytics data. Google provides some additional privacy options described at www.google.com/policies/privacy/partners/ regarding Google Analytics cookies. We may use Mixpanel to collect and process certain analytics data. More information about Mixpanel’s data practices may be found online at http://mixpanel.com/privacy/. To opt-out of Mixpanel analytics, please go to https://mixpanel.com/optout/ or review the current instructions in Mixpanel Privacy Policy.

Your Choices. You have options to control or limit how Cut+Dry and our partners use cookies and other tracking technologies. In some cases, the Site may provide a cookies management tool that allows users to reject all non-essential cookies (in which case Cut+Dry will only use the tracking technologies identified above as strictly necessary or essential). Additionally, although most browsers and devices accept cookies by default, their settings usually allow you to clear or decline tracking technologies. Note that while you can delete or block tracking technologies, if you do so, some features of the Site or Services might not work as intended. To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.

We do not assume responsibility for the functionality, accuracy, or legal compliance of any third-party opt-out tools or programs. Please note that opting out of interest-based advertising does not eliminate advertising altogether; rather, it means that any advertisements you may receive will not be personalized based on your interests. For additional information about cookies and how to manage or control them across different browsers and devices, please visit www.allaboutcookies.org.

If you have any questions regarding our use of tracking technologies, please contact us as described in the How to Contact Us section of this Policy.

Data Security

Cut+Dry takes precautions to secure your Personal Data and protect it from loss, theft, unauthorized access, destruction, use, modification and disclosure. However, please note that Cut+Dry’s security measures may change or be unavailable from time to time and no data transmission over the Internet or any wireless network is 100% secure, so we cannot guarantee the security of Personal Data.

Data Retention

Cut+Dry will retain Personal Data where we have an ongoing legitimate business need to do so (for example, to provide you with our Sites and Services, resolve disputes, and to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your Personal Data, we will either delete or aggregate it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then unless otherwise required by applicable law, we will securely store your Personal Data until deletion is commercially practicable.

VII. Children

The Sites and Services are intended for general audiences and is not directed to persons less than 13 years of age and we do not knowingly collect Personal Data from those persons. If you become aware that Personal Data about your child has been provided to Cut+Dry without your consent, please contact us.

VIII. Third Parties We Don’t Own or Control

This Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. For example, if you choose to pay through a third-party mechanism offered on our Services, the information you choose to share with that third-party will be treated in accordance with that third-party’s privacy policy. This Policy does not apply to, and we are not responsible for, for the content of such third party features or the privacy practices, including third-party cookies, web beacons, or other tracking technologies, of such third parties. We encourage you to read the privacy policies of each and every device, website, and service that you use.

Your Privacy Rights

Individual Rights. You may be entitled to exercise certain rights afforded to you under applicable data protection laws. You may contact Cut+Dry with any inquiries or requests to exercise your rights by using the contact details provided in the How to Contact Us section of this Policy. A summary of these rights is set out below. You are also encouraged to review the Region-Specific Disclosures Section of this Policy for additional information. Subject to the applicable law in your jurisdiction, you may have the following rights in relation to your Personal Data.

The Right to be Informed. You may have the right to be informed about how we process your Personal Data;

The Right to Deletion or Erasure. You may have the right to have your Personal Data deleted;

The Right to Access Your Data. You may have the right to access and receive a copy of your Personal Data and other supplementary information;

The Right to Port Your Data. You may have the right to obtain and reuse your Personal Data for your own purposes across different services and companies;

The Right to Rectify Your Data. You may have the right to correct your data if it is inaccurate or needs to be supplemented;

The Right to Object. You may have the right to object to certain types of processing, including direct marketing;

Right to Opt Out of or Withdraw Consent. You have the right to opt out of, or withdraw your consent to, certain processing activities involving your Personal Data, including the following:

– Email Marketing Communications. If you wish to withdraw your consent to the use of your Personal Data for such communications, you may unsubscribe by following the instructions in the applicable marketing emails or contact us using the How to Contact Us section of this Policy.

– Targeted Advertising and Automated Decision-Making. I.e., the processing of your Personal Data for purposes of targeted advertising or profiling, including solely automated decision-making that produces legal or similarly significant effects.

– Sale of your Personal Data (where applicable).

– Telephone or SMS Marketing Communications conducted through the Services. You may text “STOP” as instructed in the message. You may also contact us via the How to Contact Us section of this Policy.

– Postal Marketing Communications. If you wish to withdraw your consent you may contact us using the details provided in the How to Contact Us section of this Policy.

– Third-Party Supplier Communications. Where a Supplier sends you marketing or promotional communications, please follow the opt-out instructions contained in those communications or contact the Supplier directly to exercise your rights.

Right to Non-Discrimination. You may have the right not to be discriminated against for exercising any of your rights under the applicable data protection laws. However, we may offer you a different price, rate, level, quality, or selection of goods or services where you elect to opt out (including data sharing), provided that such difference is reasonably related to the value provided to us of the data.
Right Not to Be Subject to Automated Decision-Making or Profiling. You may have the right not to be subject to decisions based solely on automated processing, including automated processing for profiling or evaluations where such decisions produce legal or similarly significant effects, as defined under applicable law. Where such rights apply, you may also have the right to request human involvement, receive an explanation of the decision reached, and contest the outcome of such decision.
Right to Lodge a Complaint with a Supervisory Authority. You may have the right to lodge a complaint with a competent regulatory or supervisory authority concerning our processing of your Personal Data. Additional information is available in the Region-Specific Disclosures section of this Policy.
Right to Opt Out of the Sale or Sharing of Personal Data. While we do not sell Personal Data for monetary consideration without your consent, you may elect to opt out of the “sale” of your Personal Data or its “sharing” for targeted advertising purposes by enabling the Global Privacy Control (GPC) signal or a similar opt-out preference setting within the browser used to access our Site.
Right to Be Informed of Third-Party Disclosures (Delaware and Oregon Residents). Residents of Delaware and Oregon may have the right to request a list of specific third parties (excluding individuals) with whom we have disclosed or shared their Personal Data.

How to Submit a Request. You may exercise any of the rights described in this section, or otherwise available to you under applicable law, by contacting us via email at support@cutanddry.com or by reaching out to the Cut+Dry Privacy Office. Requests to know, access, delete, or correct Personal Data, or—where applicable for California residents—to limit the use or disclosure of Sensitive Personal Data, may be submitted through the Cut+Dry Privacy Office. California residents may also submit a “Shine the Light” request by writing directly to Cut+Dry Privacy Office. To opt out of the sale or sharing of your Personal Data, or to limit the use of your Sensitive Personal Data (to the extent the right is available), you may click the applicable link(s) made available through the Services or contact us via email at support@cutanddry.com. In addition, you may opt out of the “sale” of your Personal Data or its “sharing” for targeted advertising purposes by enabling the Global Privacy Control (GPC) signal or a similar opt-out preference setting in the browser used to access our Sites. To ensure that your preferences are honored across browsers, devices, and logged-in sessions, you may also submit a manual opt-out request by contacting us through the How to Contact Us section of this Policy.

You may designate an authorized agent to submit requests on your behalf. Authorized agents seeking to submit a request for a consumer should contact us as described in the How to Contact Us section of this Policy.

Verifying Requests. We will take reasonable measures to verify your identity before granting access to, or acting upon, any request relating to your Personal Data. If you maintain an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account and submit a request to access or delete your Personal Data, we may require you to provide certain identifying information—such as your name, email address, telephone number, or other data points maintained by us—sufficient to confirm that you are the individual about whom we have collected Personal Data, or a person duly authorized to act on that individual’s behalf.

Where you do not have an account and request access to specific pieces of Personal Data, we may additionally require you to submit a signed declaration, under penalty of perjury, attesting that you are the consumer whose Personal Data is the subject of the request. If you appoint an authorized agent to submit an access, deletion, or opt-out-of-sale request on your behalf, we may (a) require proof that the authorized agent has been granted written permission to act on your behalf, and (b) for access and deletion requests, require you to verify your identity directly with us in accordance with the procedures described above. In certain circumstances, we may deny your request or limit your rights, as permitted by applicable law. If we do so, we will notify you within the timeframes required by law (generally between 30 and no more than 90 days), provide an explanation for our decision, and inform you of your right to appeal, including instructions on how to initiate the appeal process. If we decline to take action in response to your exercise of any right described in this section, you may appeal our decision by emailing at support@cutanddry.com.

Employees of Restaurants or Suppliers. Employees should contact the appropriate person within their employer’s organization to understand, access, change and/or control what employee information is provided by the employer to Cut+Dry.

Signal Handling. Where required by applicable law, our Services are configured to recognize certain privacy preference signals, including the Global Privacy Control (GPC) and other recognized Universal Opt-Out Mechanisms (UOOMs). Upon detection, such signals automatically opt a browser or device out of the following processing activities:

the sale or sharing of Personal Data for targeted advertising purposes (where applicable) and
profiling for cross-context behavioral advertising.

Because these signals operate at the device or browser level, we encourage users to also log in to their accounts, where available, and review or confirm their privacy preferences within account settings. Please note that most mobile devices allow users to control whether location-based signals are enabled. Disabling such location signals will prevent the collection of Geolocation Data derived from the location of your mobile device and may affect the functionality or performance of certain Services. For assistance with configuring location preferences on your device, please contact your mobile service provider or the device manufacturer.

Region-Specific Disclosures

California Residents. This California Consumer Privacy Statement (the “Statement”) applies to individuals who are residents of the State of California and who qualify as a “Consumer” as defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”). This Statement describes the categories of Personal Data we collect and process, both online and offline. Certain terms used herein will have the meanings ascribed to them under the CCPA.

Notice of Collection and Use of Personal Data. We may collect, and may have collected during the twelve (12) months preceding the effective date of this Statement, the following categories of Personal Data:

Identifiers. Information such as a real name, alias, postal address, unique personal identifier (including device identifiers; cookies, beacons, pixel tags, mobile advertising identifiers, and similar technologies; customer numbers; unique pseudonyms; or user aliases), Internet Protocol (IP) address, email address, account name, telephone number, and other persistent or probabilistic identifiers.
Additional Personal Data Subject to California Civil Code § 1798.80. Information such as signature, physical characteristics or descriptions, education, and certain financial or health-related information.
Protected Classifications. Characteristics of protected classifications under California or federal law, including race, color, national origin, religion, age, sex, gender, medical condition, disability, citizenship status, military status, and veteran status.
Commercial Information. Records of products or services purchased, obtained, or considered, and other purchasing or consumption histories or tendencies.
Internet or Other Electronic Network Activity Information. Information relating to your interaction with the Site, including browsing history, search history, and other online activity.
Geolocation Data.
Employment-Related Information. Professional or employment-related information.
Inferences. Inferences drawn from any of the Personal Data described above to create a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

We may also receive or generate deidentified data (that cannot reasonably be linked to, or used to infer information about, an identified or identifiable individual). We will maintain such data in deidentified form and will not attempt to reidentify it, except as permitted or required by applicable law.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your Personal Data for the purposes described in this Policy and for the following business or commercial purposes specified in the CCPA:

Performing services on our behalf or on behalf of our customers, including maintaining or servicing accounts; providing customer support; responding to inquiries or requests for information; processing or fulfilling orders and transactions; verifying consumer information; processing payments; personalizing the Services; providing analytics services; or performing similar service-related activities.
Managing our business and for internal operational purposes.
Marketing and advertising to you.
For legal, compliance and security-related purposes.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of the Services, and to improve, upgrade, or enhance the Services.
Managing career opportunities with us.

Sources of Personal Data. During the twelve (12) months preceding the effective date of this Statement, we may have collected or obtained Personal Data about you from the following categories of sources:

Directly from you, including when you communicate with us, submit inquiries, or otherwise interact with us.
From your devices, such as when you access or use our Sites or Services, including through cookies and similar technologies.
From other individuals, such as when they provide us with your contact information in order for us to share information that may be of interest to you.
From our affiliates and subsidiaries.
From service providers that perform services on our behalf.
From Suppliers and other business partners.
From online advertising companies, advertising networks, and analytics providers.
From government entities, including public or regulatory authorities.
From social networks

iii. Selling or Sharing of Personal Data. While we do not sell your Personal Data for monetary consideration without your consent, we may allow certain third parties to collect your Personal Data through automated technologies on our Site in exchange for non-monetary consideration. We share the categories of personal information described below for the business and commercial purposes of providing our Services. Additionally, we may share Personal Data with third-party marketing and advertising partners, who may use it for marketing, commercial purposes, and platform management. For more information on how these third parties collect information, please see the “Cookies and Other Tracking Technologies” Section above. You have the right to opt out of “sharing” or “sale” of your Personal Data, as defined under California law, as explained further in this Statement. During the 12-month period preceding the effective date of this Statement, we may have sold or shared the following categories of Personal Data:

Identifiers
Commercial information
Online activity
Inferences

The foregoing categories of information may be disclosed to third parties, including Suppliers and business partners (such as service providers, advertising platforms and networks, and social media platforms), depending on the nature of a user’s interactions with our Services. In the event Cut+Dry sells or shares personal information Consumers may exercise their right to opt out of such sales or sharing by Cut+Dry by clicking the “Do not sell or share my personal information” link at cutanddry.com.

We do not knowingly sell or share the personal information of individuals under 16 years of age without explicit consent if we have actual knowledge of their age. Any users who register for an account and are under 16 are automatically opted out of the sale or sharing of their personal information.

Disclosure of Personal Information to Third Parties. During the 12-month period preceding the effective date of this Statement, we may have disclosed your Personal Data to certain categories of third parties and service providers, in addition to any disclosures described in subsection iii above regarding the sale or sharing of information. The following categories of Personal Data may have been disclosed for the commercial and business purposes described in subsection i (“Notice of Collection and Use of Personal Information”) to the categories of third parties outlined below:

Category of Personal Information	Category of Third Party
Identifiers	Suppliers; Business partners, Service providers; Government entities;
Additional Data Subject to Cal. Civ. Code § 1798.80	Suppliers and Supplier employees; Business partners, Service providers; Government entities
Protected Classifications	Suppliers and Supplier employees; Business partners, Service providers
Commercial Information	Suppliers; Business partners, Service providers; Government entities;
Online Activity	Suppliers; Service providers;
Geolocation Data	Suppliers; Business partners; Service providers
Employment Information	Service providers
Inferences	Suppliers; Business partners; Service providers

Additionally, we may disclose Personal Data to third parties as required by law, to respond to legal claims, to enforce this Policy or our Terms, or to protect the rights, property, or safety of Cut+Dry, customers or users, or the public. For the purposes of the above table “Business partners” includes (to the extent consistent with applicable law) advertisers, ad platforms and networks, and social media platforms and partners who work with us on promotional or sponsorship opportunities available through our Services, including co-branded products and services.

Enumerated California Consumer Privacy Rights. You have certain choices regarding your Personal Data as set forth in Section 9 (“Your Privacy Rights”) above and as follows.

You have the right to know what Personal Data we have collected about you, including the categories of Personal Data, the categories of sources from which the Personal Data is collected, the business or commercial purpose for collecting, selling, or sharing Personal Data, the categories of third parties to whom we disclose Personal Data, and the specific pieces of Personal Data we have collected about you.
You have the right to opt out of the sale or sharing of your Personal Data, by contacting us as set forth in Section 11 below. You may also opt-out of our sharing and selling through certain browser enabled opt-out preference signals, such as the Global Privacy Control. You can learn more about that option here: https://globalprivacycontrol.org/.
Should we ever collect “sensitive” Personal Data from you then you will have the right to limit use and disclosure of that “sensitive” Personal Data and we will enable you to do so either via a “Limit the use of my sensitive personal information” link on the Site or contacting us as set forth in Section 10 below. We may still use the information for certain limited purposes, such as the following: (i) performing our services or providing goods; (ii) detecting security incidents; (iii) resisting malicious, deceptive, fraudulent, or illegal actions; (iv) ensuring physical safety; (v) for short-term transient use, including certain non-personalized advertising; (vi) maintaining or servicing accounts, providing customer service, verifying customer information, or providing similar services; and (vii) to verify and maintain the quality or safety of a service or product or to improve, upgrade or enhance a service or product.
You may also request that we provide you with the categories of Personal Data we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and the identity of those third parties.

Additionally, California’s Shine the Light Law permits California residents to request and obtain from us once per calendar year a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and the identity of those third parties. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us.

. The following provisions supplement the general information in our Privacy Policy and apply to individuals who are residents of the states listed above and qualify as a “Consumer” (or the equivalent term) under the applicable state law:

Categories of Personal Information Processed: Please refer to the sections titled “The Information We Collect” and “How We Use Your Information” in the main body of this Policy. We may collect, process, and share “Sensitive” personal information (as defined under applicable state law) as part of our ecommerce services.

Purposes of Processing: Please refer to the section titled “How We Use Your Information” in the main body of this Policy.

iii. Categories of Information Shared: Please refer to the section titled “How We Share Your Information” in the main body of this Policy.

Third Parties with Whom Information is Shared: Please refer to the section titled “How We Share Your Information” in the main body of this Policy.

Your Privacy Rights: Depending on your state of residence, you may have certain rights under applicable state law. Please refer to the section titled “Your Privacy Rights ” in the main body of this Policy.

Financial Incentives. Our business offers programs and other initiatives that provide financial incentives in exchange for user participation, such as providing personal information. These programs may be offered directly by us or made available through the Services and managed by Suppliers. For example, our Services may allow Suppliers to operate loyalty programs for Restaurants. Participation in these programs is always optional.

When Cut+Dry administers such programs on its own behalf, the value of your Personal Data is calculated based on the return on investment or incremental margin generated from administering the financial incentives and from the use, collection, or retention of your Personal Data. If a Supplier is required to provide notice of financial incentives under the CCPA or other applicable state law, that responsibility rests with the Supplier as part of the setup and administration of its program. Please contact the relevant Supplier directly for information regarding any financial incentives they may offer through the Services or their programs.

Residents of Canada. If you are a resident of Canada, your consent to use or share your Personal Data for the additional marketing purposes described above is entirely optional and is not required to access or use the Services. If you do not wish for your Personal Data to be used or shared for these purposes, please contact the Cut+Dry Privacy Office at:

Email: support@cutanddry.com

Mail: Cut and Dry Inc., 228 Hamilton Ave., 3rd Floor, Palo Alto, CA 94301

XI. How to Contact Us

Cut+Dry welcomes questions and comments about this Privacy Policy. You can contact us by emailing us at support@cutanddry.com or mailing to us at:

Cut and Dry Inc.

Attention: Privacy Office

228 Hamilton Ave., 3rd Floor

Palo Alto, CA 94301

XII. Amendments

We may change this Policy from time to time. The most current version of this Policy will be effective at the time it is posted. By continuing to access or use the Sites or Services after those changes become effective, you agree to be bound by the revised Policy. If you have a registered account, we may notify you of any changes to our Privacy Policy via email and/or we may ask you to affirmatively acknowledge and consent to the changes the next time you use our Sites or Services.