Privacy Policy

Last modified: June 30, 2023

Protecting your privacy is very important to us.  We take our obligation to safeguard and secure personal information very seriously. We want you to understand how we protect your privacy and when we collect and use information.

The Privacy Policy describes how GS Foods Group, Inc. and our subsidiaries and affiliates (“GS Foods”, “we”, “us”, or “our”) collect, store, use and disclose personal information about you when you interact with us by visiting or using our websites (“Site”); contact our customer service team; communicate with us; use, request, purchase, obtain or consider our products, or otherwise interact with us.

Collectively, we refer to the above as our “Services.” Additional or different privacy notices may apply to certain of our Services. If a different or supplemental privacy notice applies, this will be disclosed to you.

See the California Privacy Rights section below for important information about your personal information and rights under applicable state privacy laws.

This Privacy Policy does not apply to the personal information that we collect about employees and other personnel related to their working relationship with us.  Please click here to review our Employee Privacy Notice. Please click here to review our Applicant Privacy Notice.  We may also collect, generate, use, and disclose aggregate, anonymous, and other non-identifiable data related to our Services, which is not personal information subject to this Privacy Policy.

If you have any questions, please contact us as provided below. You may download a copy of this Privacy Policy by clicking here.  If you need to receive this Privacy Policy in a different format, please contact us at (888) 671-9626 or HRPrivacy@GSFoodsGroup.com

Please read this Privacy Policy carefully to understand our policies and practices. By using the Site or providing your personal information to us, you signify that you consent to the use of your information in accordance with this Privacy Policy. If you do not agree with any term in this Privacy Policy, you should not access and use the Site and please do not otherwise provide us with any personal information.

Categories of Personal Information We Collect
Sources Of Personal Information
Purposes for Collecting Personal Information
How We Disclose Personal Information
Sensitive Personal Information
How Long We Keep Personal Information
Links to Other Websites
Security
This Website is Not Intended for Minors
Choices About How We Use and Disclose Your Information
Processing in the United States
California Privacy Rights
Contact Us
Updates to Our Privacy Policy
Notice At Collection to Website Visitors

The type of information that we collect depends on your interaction and relationship with us.  For example, personal information may be collected when you fill out a ‘Contact Us’ form on our Site or otherwise provide us personal information through the Site and Services.  We collect, and in the preceding 12 months have collected, the below categories and types of personal information with your consent or as otherwise required or permitted by law.

• Identifiers, such as your name, email address, current and prior address, Internet Protocol (“IP”) address, account name, telephone number, business contact information, and title/position.
• Commercial Information, such as records of products or services purchased, obtained, or considered and purchasing histories by you on behalf of the business(es) you represent in connection with our Services.
• Internet or Other Electronic Network Activity Information, such as your website interaction history, a date/time stamp, browser type, device type, device ID, referring/exit URLs, operating system, language, clickstream data, the pages you visit, the time and date of your visit, the time spent on each page, and other information about the links clicked, features used, and similar device and usage information. We also collect “cookies”, tracking pixels, and similar technologies.  What we collect can depend on the individual settings of your device and software.
• Professional or Employment-Related Information, such as who you work for and your position with your employer.
• Audio/Visual Data or Similar Information, such as security camera footage and voicemails

We collect, and in the preceding 12 months have collected, personal information in the following ways:

• Directly from you. We collect identifiers, commercial information, audio/visual data, and professional or employment information, that you provide directly to us.  This includes information provided at the time of registering to use our Site, subscribing to our Services, communicating with us, or requesting further Services.
• When you visit our locations. When you visit our offices or facilities, we also collect identifiers and audio/visual data.
• Automatically. When you access our Site, we collect internet or electronic usage data using tools like functional cookies.  Information collected automatically may also include IP addresses, and information collected through cookies.
• From third parties. We may collect identifiers, commercial information, and professional or employment information, from third-parties including our business contacts, vendors, customers, recruiters, suppliers, and service providers.
• From our employees. We collect identifiers, commercial information, professional or employment information, and education information from our employees.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Site(s), we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Site, including traffic data and other communication data and the resources that you access and use on the Site.
• Information about your computer and internet connection, including your operating system and browser type.

The information we collect automatically may include personal information.  It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). Cookies are small files that are stored on your device used to access our services. They help us personalize your experience when you return to our Site, and they are required for certain portions or functionality of our Site. 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 Site. 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 Site.
• Web Beacons. Pages of our Site 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 website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We use personal information for the following purposes:

• Providing our Services. We use identifiers, commercial information, audio/visual data, and professional and employment information to facilitate the generation of new business opportunities, to allow customers to contract for and purchase our Services, to provide the products and Services we have contracted for, and to provide updates and reports requested by customers.
• Transactional Purposes. We use identifiers, professional or employment information, and commercial information to: (i) communicate with you; (ii) provide you with customer assistance; (iii) administer contracts with our vendors, customers, suppliers, and service providers; and (iv) provide supporting business activities such as billing and collections, and procurement related activities.
• Business Operations. We use identifiers, commercial information, audio/visual data, professional or employment information, education information, and internet or other electronic network activity information, for our day-to-day business operations including maintaining records, managing and securing our facilities, planning, budgeting, calibration, headcount, database administration, surveys, evaluations, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.
• Marketing and Promotional Purposes. We use identifiers, professional or employment information, internet or other electronic network activity information, and commercial information to improve our marketing efforts, conduct market research, prospect for new clients, engage in client relationship management, client engagement, administering promotions, and to provide you with information about us, including relevant marketing communications.
• Maintenance and Improvement of our Site and Systems. We use identifiers and internet or other electronic network activity information to improve our Site and systems, provide and maintain functionality on our Site and systems, and help us diagnose technical and service problems and administer our Site and systems.  Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing IT support services
• Develop and Improve Our Services. We use commercial information to help us develop new products and services and to improve and analyze our existing service offerings.
• Security and Fraud Prevention. We contact identifiers, commercial information, internet or other electronic network activity information, audio/visual data, professional or employment information, and education information to: (i) protect us, our employees, and our Site, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; (iii) conduct vendor and customer due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
• Complying with Legal and Ethical Obligations and Legal Process. We use identifiers, commercial information, internet or other electronic network activity information, audio/visual data, and professional or employment information to comply with our legal obligations, including responding to requests under the CCPA, reporting requirements and responding to court orders, warrants, or subpoenas, defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings

We disclose personal information in the following circumstances:

• Service Providers. We may share personal information with vendors and service providers who support the operation of our Services, Site, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, order fulfillment, email delivery, marketing, insurance, operating systems and platforms, transportation, and customer support services).  In some cases, the vendor or service provider may directly collect the information from you on our behalf.  In the past 12 months, we have disclosed, identifiers and commercial information to our service providers.
• Professional Advisors. We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us. In the past 12 months, we have disclosed identifiers, commercial information, and internet or other electronic network activity information to our professional advisors.
• Government Entities. We may share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.  In the past 12 months, we have not disclosed any personal information to government entities.
• Corporate Transaction Recipients. We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.
• Affiliates. We may share some or all of your personal information with our parent company, subsidiaries, and other companies under common ownership or control with us for purposes consistent with this Privacy Policy.
• Other Reasons. We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.

Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).

We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests).  We use the following criteria to determine retention periods:

• how long the information is needed to provide our services and operate our business;
• whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
• whether any law, statute, or regulation allows for a specific retention period;
• whether an individual has agreed to a longer retention period;
• whether the data is considered to be sensitive data; and
• what the expectation for retention was at the time the data was provided to us.

Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

Our Site is not intended for use by individuals under the age of 16.  We do not knowingly collect or store any personal information from anyone under the age of 16.  If we become aware that we have collected or stored personal information from an individual under age 16, we will remove their personal information from our files.  If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us at (888) 671-9626 or HRPrivacy@GSFoodsGroup.com

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Site(s) may then be inaccessible or not function properly.

Marketing Emails.  If you do not wish to have your email address/contact information used by us to promote our own Services, you can opt-out by sending us an email stating your request to HRPrivacy@GSFoodsGroup.com   If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to us as a result of a product purchase, product service experience or other transactions.

Text Messages. You can opt out of receiving commercial or promotional text messages by changing the preferences on the GSFoodsGroup Platform, logging out or deleting the GSFoodsGroup Platform from your registered device.

Please be aware that information we obtain about you will be processed in the United States by our service providers or us.  By using the Site or our Services or otherwise providing us with your personal information, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in this Privacy Policy.  Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other jurisdictions may be different from the laws in your country of residence.  The United States may not afford the same level of protection as laws in your own country.

If you are a California resident, this section applies to you.

Shine The Light.  The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes.  If you are a California resident and would like to make such a request, please contact us at HRPrivacy@GSFoodsGroup.com and include “CA Shine the Light” in the subject line of your email.  We do not currently disclose your personal information to third parties for their own direct marketing purposes.

California Consumer Privacy Act (“CCPA”), as Amended by the California Privacy Rights Act.

Sale or Sharing of Personal Information.  In the preceding 12 months, we have not “sold” or “shared” (as those terms are defined in the CCPA) any personal information to “third parties”, as that term is defined in the CCPA.  We do not knowingly sell or share the personal information of minors under the age of 16.

Use or Disclosure of Sensitive Personal Information.  We do not collect sensitive personal information from you.

Your Rights Under the CCPA.  Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:

• You have the right to request that we tell you (i) what personal information we have collected about you, (ii) the sources of that information, (iii) the purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed personal information.
• You have the right to request that we provide you with a copy of your personal information.
• You have the right to request that we delete personal information that we have collected from you. We may not delete all of your personal information if one of the exceptions to the CCPA applies.
• You have the right to correct inaccurate personal information that we hold about you.
• You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.

Exercising Your Rights.  To exercise any of your rights, please email us at HRPrivacy@GSFoodsGroup.com, or use the webform here on our Site to submit a request.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.  You can ask to appeal any denial of your request in the same manner through which you may submit a request.

For all requests, you should provide us with sufficient information to verify your identity and process your request.  Failure to provide identifying information may prevent us from processing your request.  If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.

Authorized Agents.  Your authorized agent may be able to make a request on your behalf.  However, we may need to verify your authorized agent’s identity and authority to act on your behalf.  We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

If you have any questions about this Policy or our privacy practices, please email us at (888) 671-9626 or HRPrivacy@GSFoodsGroup.com

This Privacy Policy may be updated from time to time for any reason. If we make material changes to this Privacy Policy we will notify you by posting the new Privacy Policy here and changing the last modified date listed at the top of this Privacy Policy. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner through the Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version as described above (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

This Privacy Policy applies to all of the following GS Foods Group, Inc. companies:

• Gold Star Foods
• Good Source, Solutions
• GS Foods Group

This Notice explains your rights under the CCPA and helps you understand how we collect and use your personal information when you use our Site and submit information through our webform.

1. Information We Collect From Website Visitors

When you use our Site we collect personal information in the form of Internet or Other Electronic Network Activity Information, such as your device ID, internet and network information, and cookie information.  This personal information is collected automatically from the device you use to access our Site.

Personal information, including identifiers such as your name, email address, and telephone number, may be collected when you fill out a ‘Contact Us’ form on our Site or otherwise provide us personal information through the Site and Services.  If you submit a CCPA request through the webform on our Site, we may also collect personal information in the form of Identifiers, such as your name, email address, and telephone number.

2. How We Use the Information We Collect

We use the personal information we collect on our Site for the following purposes:

• Business Operations. We use identifiers and internet or other electronic network activity information for our day-to-day business operations including maintaining records, database administration, evaluations, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.
• Marketing and Promotional Purposes. We use identifiers to improve our marketing efforts, conduct market research, prospect for new clients, engage in client relationship management, client engagement, administering promotions, and to provide you with information about us, including relevant marketing communications.
• Providing our Services. We use identifiers to facilitate the generation of new business opportunities, to allow customers to contract for and purchase our Services, to provide the products and Services we have contracted for, and to provide updates and reports requested by customers.
• Transactional Purposes. We use identifiers to: (i) communicate with you; (ii) provide you with customer assistance; (iii) administer contracts with our vendors, customers, suppliers, and service providers; and (iv) provide supporting business activities such as billing and collections, and procurement related activities.
• Maintenance and Improvement of our Site and Systems. We use internet or other electronic network activity information to improve our Site and systems, provide and maintain functionality on our Site and systems, and help us diagnose technical and service problems and administer our Site and systems.  Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing IT support services
• Security and Fraud Prevention. We use identifiers and internet or other electronic network activity information to: (i) protect us, our employees, and our Site, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; and (iii) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
• Complying with Legal and Ethical Obligations and Legal Process. We use identifiers and internet or other electronic network activity information to comply with our legal obligations, including responding to requests under the CCPA, reporting requirements and responding to court orders, warrants, or subpoenas, defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.

3. Additional Rights Under California Law

You may have certain rights under California law. This may include a right to access, correct, or delete certain personal information we collect about you, subject to applicable exceptions.  To exercise your rights, you may email us at HRPrivacy@GSFoodsGroup.com, or use the webform here on our Site to submit a request.

Under California law, we are required to tell Californians if we “sell” or “share” information as that term is defined by applicable law. Sell is defined under the law as disclosing personal information to a third party for monetary or other valuable consideration. Share is specifically defined under the law as well. Sharing means sharing personal information with a third party for cross-context behavioral advertising.

We do not do “sell” or “share” data collected on our Site, based upon our understanding of those terms.  If you interact with us in other ways, you may have different rights. If you are a customer or consumer, the Privacy Policy on our Site applies to our interactions with you as a customer or consumer.

4. How We Retain Your Personal Information

To the extent permitted by applicable law, we will retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any business, legal, accounting, or other reporting requirements or obligations.  We use the following criteria to determine retention periods:

• how long the information is needed to provide our services and operate our business;
• whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
• whether any law, statute, or regulation allows for a specific retention period;
• whether an individual has agreed to a longer retention period;
• whether the data is considered to be sensitive data; and
• what the expectation for retention was at the time the data was provided to us.

5. How You Are Protected Against Discrimination

We will not unlawfully discriminate against you for exercising any of your rights under the CCPA.

6. Disclaimer

Nothing in this Notice restricts our ability to:

• Comply with federal, state, or local laws;
• Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
• Exercise or defend legal claims;
• Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
• Transfer personal information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of our family of companies.

7. Changes to This Notice

This Notice is reviewed and updated annually to ensure it accurately captures our practices and procedures. The effective date of this version is posted at the top of the Privacy Policy.

8. Privacy Policy

Please click here to view our Privacy Policy.

9. Resolving Concerns and How to Contact Us

If you have questions or concerns regarding this Notice or the handling of your personal information, please contact us at (888) 671-9626 or HRPrivacy@GSFoodsGroup.com