ButcherBox Supplemental Privacy Policy

ButcherBox
Supplemental Privacy Policy
California, Virginia, Colorado, Connecticut, Utah

Last Revised on: 3/17/23

This Supplemental Privacy Policy and Notice (“Supplemental Policy”) applies only to information collected about consumers residing in California, Colorado, Virginia, Utah, or Connecticut (“consumer(s),” “Consumer(s),” “you,” “your”) and supplements the information contained in ButcherBox’s bbgoodpets.com Privacy Policy. It provides information required under the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), the Colorado Privacy Act of 2021 (the “CPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), and the Connecticut Data Privacy Act of 2022 (“CDPA”) and any and all regulations arising therefrom.

This Supplemental Policy describes the practices of ButcherBox OpCo, LLC (collectively, “ButcherBox”, BB Good”, “we,” “us,” or “our”) regarding the collection, use, and disclosure of personal information and provides instructions for submitting data subject requests. Some portions of this Supplemental Policy apply only to consumers of particular states, and we have indicated where those portions are state-specific.

If you are unable to review or access this Supplemental Policy due to a disability, you may contact ButcherBox at (855) 981-8568 or legal@butcherbox.com to access this Supplemental Policy in an alternative format.

Definitions Specific to this Policy

“Consumer” means a natural person who resides in California, Colorado, Virginia, Utah and Connecticut and to whom we offer information, goods, or services. For purposes of this Supplemental Policy, this term includes natural persons who reside in California and engage with us as part of business-to-business transactions.
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes “personal data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA. Personal Information also includes “Sensitive Personal Information,” as defined below.
“Sensitive Personal Information” means Personal Information that reveals a Consumer’s: 1) Social security, driver’s license, state identification card, or passport number; 2) Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; 3) Precise geolocation; 4) Racial or ethnic origin; 5) Religious beliefs; 6) Union membership; 7) Contents of email or text messages, unless we are the intended recipient; 8) Genetic data; 9) Biometric information used to uniquely identify the Consumer, and 10) Health, sex life, or sexual orientation. Sensitive Personal Information includes “sensitive data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA.
“Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for money or other valuable consideration.

“Share,” “Shared,” or “Sharing” means transferring an individual’s Personal Information to a Third Party for behavioral advertising purposes, whether or not for money or other valuable consideration.
“Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us and as defined by the CCPA, CPA, VCDPA, UCPA, and CDPA.
“Vendor” means a “service provider,” “contractor,” or “processor” which collects, stores, or otherwise handles data for us, as those terms are defined in the CCPA, CPA, VCDPA, UCPA, and CDPA.

These definitions apply, whether terms are capitalized or not. Other terms used in this Supplemental Policy may be defined under the CCPA, CPA, VCDPA, UCPA, or CDPA, and they shall have the meanings described in those statutes. If there are variations between such definitions in different laws, you will be covered by the definition that applies in your state. For example, if you are a Virginia consumer, terms defined in the VCDPA shall apply to you if they are used in this Supplemental Policy.

The Personal Information We Collect and Disclose

The chart below shows the categories of personal information we may collect; examples of personal information in each category; types of sources from which each category of personal information is collected; the business purposes for which each category of personal information is collected; and the types of Vendors or Third parties with whom that category of personal information is shared. As this chart shows, we may share or sell personal information to Third Parties or disclose certain personal information to Vendors for business purposes.

Category of Personal Information	Examples	Sources from Which This Personal Information is Collected	Business Purposes for Collection	Types of Vendors or Third Parties with Whom This Personal Information is Shared, Sold or Disclosed
Unique Identifiers	Name, address, telephone, email, account name, online identifier, IP address	The consumer directly; Marketing systems (cookies, pixels, IP, etc.);	Customer support; Credit card processing; Digital marketing (including creation of custom targeted audiences); Social media advertising; Shipping / order fullfillment; and Order Proccessing	Disclosed: Fulfillment partners; Shipment providers; Email service providers; Customer service providers; and Payment providers. Shared: Digital marketing; and Social media platforms and influencers
Contact and Financial Information	Name, address, telephone, email, credit card number, debit card number, or any other financial information	Directly from you via our website Claims management providers	Complete transactions Other services and discounts Process claims	Disclosed: Payment process Mailing houses Shared or Sold: None
Characteristics of Protected Classifications	Characteristics of protected classifications under state laws or federal law, including: race, ancestry, national origin, age (40 years or older), marital status, sex, sexual orientation, medical condition, disability, genetics, and veteran or military status	May be inadvertently disclosed by Member directly to ButcherBox Customer Support Individuals	Customer Service;	Disclosed: Customer service providers. Shared or Sold: None
Commercial Information	Records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Directly from Customers	Customer service; Experience management; and Digital marketing (including the creation of custom targeted audiences).	Disclosed: Marketing consultants Contactors Fulfillment providers Business partners Marketing platforms Shared or Sold: None
Internet or Other Electronic Activity	Internet or other electronic network activity information, including, but not limited to, and information regarding a consumer’s interaction with our Internet Web site, application, or advertisement	Directly from customers;	Provide you with goods and services Invite participation in surveys and feedback; Customer service communications Improve promotions (including the creation of custom targeted audiences).	Disclosed: Web hosting platforms Contractors Customer data platforms Email service provider Shared or Sold: None
Geolocation Data	Device location; browser; and IP address	From your digital device; Direct communication with you	Provide you with goods; Customer service communications; Improve promotions; Product availability	Disclosed: Service providers Fulfillment providers Shipment providers Shared or Sold: None
Audio, Electronic, Visual, Thermal, Olfactory, Or Similar Information	Call recordings; voluntary video recordings	Directly from Customer to Customer Support Individuals; From call center providers.	To record customer service/experience interactions.	Disclosed: Service providers Shared or Sold: None
Inferences Drawn from Other Categories to Create a Profile	Profile reflecting preferences; predispositions; surveys; and behavior	The consumer directly; Digital marketing companies	Digital marketing (including the creation of custom targeted audiences); Customer support Customer experience enhancements	Disclosed: Business partners (email only) Shared or Sold: None

Sensitive Personal Information We Collect and Disclose

Category of Sensitive Personal Information

Sources From Which This Sensitive Personal Information is Collected

Business Purposes for Collection

Types of Vendors or Third Parties with Whom This Sensitive Personal Information is Shared, Sold or Disclosed

Account log-in, financial account, debit card number, plus an access code

Directly from you via our website

Completed Transactions

Disclosed:

Payment processor

Shared or Sold:

None

RETENTION OF DATA

We intend to retain each category of personal information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average consumer’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain personal information: why we collected the personal information; the nature of the personal information; the sensitivity of the personal information; our legal obligations related to the personal information, and risks associated with retaining the personal information.

Your Rights to Your Personal Information

California, Colorado, Virginia, Utah, and Connecticut consumers have certain rights with respect to the collection and use of their personal information. Those rights vary by state. As required by the CCPA, we provide detailed information below regarding the data subject rights available to California consumers. Consumers in Colorado, Virginia, Utah, and Connecticut have similar rights and can find more detail by referencing the CPA, VCDPA, UCPA, or CDPA, as applicable.

You have the right to submit requests related to the personal information we have collected about you. You may make such a request twice in a 12-month span. Please note, there are circumstances when we may not be able to comply with your request. For example, we may not be able to verify your request or we may find that providing a full response conflicts with other legal obligations or regulatory requirements. We will notify you if this is the case.

Right to Receive Information on Privacy Practices. You have the right to receive the following information at or before the point of collection:

The categories of personal information to be collected;
The purposes for which the categories of personal information are collected or used;
Whether or not that personal information is sold or shared with Third Parties or disclosed to Vendors;
If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and

The length of time the business intends to retain each category of personal information, or if that is not possible, the criteria used to determine that period.

We have provided such information in this Supplemental Policy, and you may request further information about our privacy practices by using the contact information provided below.

Right Know and Right to Access. You have the right to request certain information we have collected about you. You have the right to request:

Specific pieces and categories of personal information we collected about you;
The categories of sources from which personal information was collected;

The purposes for which personal information was collected, shared, sold, or processed;
The categories of personal information we shared, sold or disclosed; and
The categories of Vendors or Third Parties with whom we shared, sold or disclosed personal information.

Right to Delete. You have the right to request that we delete certain personal information that we have collected.

Right to Correct. You have a right to request that we correct any inaccurate personal information we may retain about you.

Right to Opt-Out of the Sale and Sharing of Your Personal Information. You have the right to opt-out of the sale and sharing of your personal information with Third Parties, and the right to opt out of the processing of personal information for targeted advertising purposes, as defined in the CCPA, CPA, VCDPA, UCPA, and CDPA.

We sell and share personal information, or process personal information for targeted advertising purposes. In the past 12 months, we have sold or shared the categories of consumer personal information as listed in this Supplemental Policy. As a consumer, you have the right to opt-out of the sale and/or sharing of your personal information and of the processing of personal information for the purpose of targeted advertising. To submit an opt-out request, please access the below link or follow the “Instructions to Exercise Your Rights,” below. We do not knowingly sell or share personal information of consumers under 16 years of age.

["Do Not Sell or Share My Personal information"]

If you opt-out of the sale of your personal information, we will wait at least 12 months before asking you if we may sell or share your personal information.

You have the right to opt-in to the sale of your personal information after you have opted out. If you would like to opt-in to the sale or sharing of your personal information, please email us at appeals@butcherbox.com. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.

Right to Consent to or Limit the Use of Your Sensitive Personal Information. You have the right to consent to the use of your Sensitive Personal information in CO, CT, VA and UT. Separately, you have the right in CA to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average consumer or for specific business purposes defined by law.

We use Sensitive Personal Information with your consent, and for the purposes listed in the “Sensitive Personal Information We Collect and Disclose” chart above. You have the right to further limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA. To submit a request to limit the use of your Sensitive Personal Information, please access the below link.

Right to Non-discrimination. You have a right to exercise the above rights, and we will not discriminate against you for exercising these rights. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests.

Instructions to Exercise your Rights. If you would like to make any of the data requests listed above, please click here. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify. If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request, and the level of verification will depend on the request being submitted. You may also submit a request by emailing us at legal@butcherbox.com.

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Such individual must have power of attorney, or be an authorized agent registered with the relevant Secretary of State.

Right to Appeal. You have the right to appeal our decisions about your data subject requests. If you choose to appeal, your request will move from Customer Support to our Legal Department for review. If you would like to appeal a decision regarding your data request, please click appeals@butcherbox.com. Please state that your request is an “Appeal,” and describe the date and nature of your original request.

Verification Process

When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity.

If you designate an authorized agent to exercise your rights on your behalf, we may require that you or the authorized agent do the following:

Verify your identity with us directly.
Provide proof of your signed written permission for the authorized agent to submit a request on your behalf.

We may deny a request from an agent purportedly acting on your behalf if we request, and the agent does not submit, proof that he, she, or it has been authorized by you to act on your behalf.

Personal Information of Minors

Our online content is not intended for children or minors under the age of sixteen years. Accordingly, we do not knowingly store information from minors under the age of sixteen years, except as required by applicable law. If you believe that a child has submitted personal information to us, please contact us at: legal@butcherbox.com. and we will delete the information.

Additional California Privacy Rights

Shine the Light Request. California Civil Code Section § 1798.83 permits users of our website who are California residents to request information about our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to legal@butcherbox.com with the subject “Shine the Light Request.”

Changes to Our Supplemental Policy

ButcherBox reserves the right to amend this Supplemental Policy at our discretion and at any time. When we make changes to this Supplemental Policy, we will post the policy on our website with a new Last Updated date.

Additional Information

If you would like additional information regarding our Supplemental Policy, please contact us at legal@butcherbox.com, (855) 981-8568, or ButcherBox at 311 Arsenal Street Watertown, MA 02472.

Return to the start of our Supplemental Policy[link]