Privacy Policy

Effective Date

July 1, 2020

Thank you for visiting this website (this “Site”), which is owned by Wells Enterprises, Inc. (“Wells,” “we,” “us,” or “our”).

TABLE OF CONTENTS

1) SCOPE OF THIS POLICY

This Privacy Policy describes the information we collect about you. Our Privacy Policy applies to information related to you that may be collected by or for

online at blueribbonclassics.com (the “Site”);
through the activities of our iScream Team;
for our sweepstakes, contests and surveys;
through our registration and event services; (collectively, “Services”).

Our Privacy Policy describes:

the categories of Personal Information we and our Providers collect;
how we collect, use and secure this information;
when we share this information with third parties, including relevant Providers;
the purposes for which your Personal Information may be used; and
choices you can make and rights you have about how we collect and use certain information.

2) YOUR CONSENT

Please take a few minutes to review this Policy before using this Site. By using this Site, you are consenting to the collection, use and disclosure of your information as set forth in this Policy. If you do not agree to be bound by this Policy, you may not access or use this Site.

3) THIS POLICY IS PART OF OUR TERMS OF USE

This Policy is part of the Terms of Use that govern your use of this Site. A link to our Terms of Use is provided at the bottom of each page of this Site.

4) TYPES OF INFORMATION WE COLLECT

Personal Information
We collect various types of information about and related to you. In general, we may collect and store “ Personal Information” directly (for example, when you create a customer account) or indirectly (for example, when you visit our Site) from you. Personal Information is information that reveals your specific identity or directly relates to you as an individual. Personal Information we collect may include your name, postal address, email address, phone number, IP address, credit and debit card information (and related payment information), account username and password.
Automatically Collected Information

When you use certain Services, we use cookies, web beacons, pixel tags, social media widgets and other automated information collection and tracking technologies to collect and store certain types of Personal Information (“Automatically Collected Information”).

Automatically Collected Information includes information such as:

Technical information, like your IP (internet protocol) address, the type of browser, device or hardware you are using, including device model, operating system version, unique device identifiers and mobile network information.
Your interactions with certain Services, like how you use our Site or App, including the time you spend on these Services, the way you navigate through these Services and search terms you enter when using these Services.
Your interactions with the ads we serve, including through your interaction with our content presented on a third-party website or mobile application.
Your geo-location, including the precise location of your device.

5) HOW WE COLLECT YOUR INFORMATION

We collect Personal Information related to you:

We receive Automatically Collected Information about you when you use our Services where automated information collection and tracking technologies have been employed by us or by our Providers, such as: If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if your browser rejects our cookies.

from you when you provide such information to us.
through technology-enabled collection and tracking services that allow us to automatically collect certain information when you use our Site or App or interact with our emails, social media or advertisements on our Site, our App or other websites.
from third party sources, including vendors who perform a business, professional or technical support functions for us.

Information You Provide Us
We receive and collect Personal Information from you when you use our Services, such as in the following circumstances:
Please note, when you use a third-party website or mobile application in connection with our Services, you may be further subject to such third party’s terms of use, privacy policy and/or other applicable terms and conditions.
- When you create a customer account on our Site, we may collect:
  - identifiers such as your postal address, online identifier, IP address, email address, or account name;
  - Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80 et. seq.) such as your name, alias, telephone number or home address;
  - commercial information such as your purchasing habits and histories;
  - Internet or other similar network activity such as your browsing history, search history, information on your interaction with our Site;
  - geolocation data such as your physical location or movements; or
  - inferences drawn from other Personal Information to reflect your preferences, characteristics, trends or aptitudes.
- When you participate in customer research and surveys, we may collect:
  - identifiers such as your postal address, online identifier, IP address, email address, or account name; or
  - Personal Information categories listed in the California Customer Records statute such as your name, alias, telephone number or home address.
- When you participate in sweepstakes or promotions we offer, we may collect:
  - identifiers such as your postal address, online identifier, IP address, email address, or account name; or
  - Personal Information categories listed in the California Customer Records statute such as your name, alias, telephone number or home address.
- When you subscribe for communications from us, such as promotional emails, we may collect:
  - identifiers such as your postal address, online identifier, IP address, email address, or account name; or
  - Personal Information categories listed in the California Customer Records statute such as your name, alias, telephone number or home address.
- When you contact us through any method, including by phone, email, web chat and fax, we may collect:
  - identifiers such as your postal address, online identifier, IP address, email address, or account name; or
  - Internet or other similar network activity such as your browsing history, search history, information on your interaction with our Site;
  - Personal Information categories listed in the California Customer Records statute such as your name, alias, telephone number or home address.
- When you use a third-party website or mobile application (such as a social media platform) in connection with our Services, we may collect:
  - identifiers such as your postal address, online identifier, IP address, email address, or account name; or
  - Internet or other similar network activity such as your browsing history, search history, information on your interaction with our Site;
  - Personal Information categories listed in the California Customer Records statute such as your name, telephone number or home address.
Please note, when you use a third-party website or mobile application in connection with our Services, you may be further subject to such third party’s terms of use, privacy policy and/or other applicable terms and conditions.
Information from Technology-Enabled Collection Services

Information From Third-Party Social Media Platforms. You may be able to register with, log on to, or enhance your profile on this Site by choosing to automatically populate the requested data fields with information you previously provided to a third-party social media platform (such as Facebook or Twitter). By doing this, you are asking the third-party platform to send us information, including Personal Information, from your profile on that platform.
Information from your browser or device. Wells may collect information that is sent to us automatically by your web browser or mobile device. This information typically includes your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. The information we receive may depend on your browser or device settings.
The information we may receive from your web browser and device. We may combine it with other information in an attempt to identify you or we may combine it with information that does identify you. We may also review our server logs for security purposes—for example, to detect intrusions into our network—and we might share our server logs, which may contain visitors’ IP addresses, with the appropriate investigative authorities who could use that information to trace and identify you.
Information Collected by Cookies and Other Technologies. A “cookie” is a small file placed on your device when you visit a site that can be understood by the site that issued the cookie. We may use cookies and other technologies to collect information and support certain features of this Site. For example, we may use these technologies (including third-party cookies, described below) to:
- collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page;
- determine how you interact with emails we send to you, including whether you click on any links within the email;
- support the features and functionality of this Site—for example, to save you the trouble of reentering information or to prompt the settings you established on previous visits;
- personalize your experience when you use this Site; and
- improve our marketing efforts, including through use of targeted advertising and email marketing.

6) INFORMATION ABOUT THIRD-PARTY COOKIES; TARGETED ADVERTISING

In addition to the cookies Wells may deliver to your computer or mobile device through this Site, certain third parties may deliver cookies to you for a variety of reasons. For example, we may use Google Analytics, a web analytics tool that helps us understand how visitors engage with our Sites. To learn more about Google Analytics, click here. Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Site or on other websites.
You have choices about the collection of information by third parties on this Site. For example, if you don’t want information about your visit to this Site sent to Google Analytics, you may download an Opt-out Browser Add-on by clicking here. Please note that the Add-on does not prevent information from being sent to Wells.
In addition, if you would like to opt-out of having interest-based information collected by certain entities during your visits to this Site or other websites, please click here for a “Website Opt Out.” You will be directed to an industry-developed website that allows you to choose whether each listed entity may collect and use data for interest-based advertising purposes. It may be that some of the third parties that collect interest-based information on this Site do not participate in the Website Opt Out, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies.
The Website Opt Out described above works only on websites. To opt out of having participating entities track your behaviors for advertising purposes when you are using a mobile app, download and use the Digital Advertising Alliance’s “App Choices” app. As with the Website Opt Out, the “Mobile App Opt Out” prevents tracking only by participating entities.
Please note that the Website Opt Out and Mobile App Opt Out are device specific and the Website Opt Out is browser specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need take the steps outlined above from each device and browser.

7) HOW WE USE INFORMATION COLLECTED THROUGH THIS SITE

Generally, we use the information we collect through this Site: Please see below for information about the choices you have about the ways we use your information.

to provide the information, products and services you request;
for security, credit or fraud prevention purposes;
to provide you with effective customer service;
to provide you with a personalized experience when you use this Site;
to contact you with information and notices related to your use of this Site;
to contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
to invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
to better understand your needs and interests;
to improve the content, functionality and usability of this Site;
to improve our products and services;
to improve our marketing and promotional efforts; and
for any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

8) YOUR CHOICES

In General. We respect your right to make choices about the ways we collect, use, and disclose the information you provide on or through this Site. We strive to provide choices to you at a meaningful time and in a meaningful place. This Policy describes some of your other choices, such as your choice to opt out of receiving “cookies.”
Do Not Track Mechanisms. Your browser may deliver a “Do-Not-Track (‘DNT’) signal” to this Site. Because of the changing state of technology and indecision within the technology and marketing industries regarding the meaning of DNT signals, we currently do not make any guarantee that DNT signals will be honored.
Previously Expressed Preferences. You may change previously expressed preferences regarding how we use information you provide on or through this Site. For example, if you have provided your contact information and receive periodic emails from us, you may decide to stop receiving those emails by clicking the “unsubscribe” link in an email’s footer. You may be able to change other preferences through an account you create on this Site. Otherwise, please contact us using the information provided below.

9) HOW TO ACCESS, UPDATE OR CORRECT YOUR INFORMATION

If you have created a profile on this Site, you may be able to access, update or correct your information through your account settings. Otherwise, you may need our help. Please contact us using the information provided below. We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identity. If you seek deletion of information that you posted when you were a minor, please contact us using the information provided below.

10) STEPS WE TAKE TO SAFEGUARD YOUR INFORMATION

Our Security Practices. We maintain reasonable administrative, physical and technological measures to protect the confidentiality and security of Personal Information you submit on or through this Site. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your Personal Information will not be disclosed, misused or lost by accident or by the unauthorized acts of others. Further, we cannot control dissemination of Personal Information you post on or through this Site using any social networking tools we may provide, and you should have no expectation of privacy in such information.
Your Security Practices. You are also responsible for taking reasonable steps to protect your Personal Information against unauthorized disclosure or use.
We encourage you to take steps to help protect the confidentiality and security of your account and Personal Information, including by doing the following: You may come into contact with emails, texts or mobile alerts that look like they originate from us asking for your Personal Information. For your protection, do not respond to such communications or click on links or open any files attached to such suspicious, unsolicited communications. If you receive such a communication, contact us so that we may investigate the suspicious activity.

Install the latest security updates and antivirus software on your computer to help prevent malware and viruses;
Use complex passwords and not using the same password on more than one Site;
Password protect your computer and mobile device;
Do not share your passwords with others; and
Sign out/log off Site sessions to close your session.

11) HOW WE SHARE INFORMATION WITH OTHERS

We may share your Personal Information we collect with third parties for other purposes, such as in the following ways:

As Described in a Privacy Notice. We reserve the right to disclose your information as described in any privacy notice posted on this Site.

With Third–Party Vendors. Wells shares information collected through this Site with third-party vendors who act on our behalf (“Providers”). For example, we may use third-party vendors to design and operate this Site; to conduct surveys; to perform analytics; and to help us with our promotional efforts. These third-party vendors may need information about you to perform their obligations. Typically, they are required by contract to keep your information confidential and to use it only to provide services on our behalf; however, as described below, we may allow them to use aggregate or de-identified data for their own purposes or to market the products and services of their other clients.
With Third-Party Social Media Platforms. We may provide functionality on this Site that allows you to automatically post information to a third-party social media platform (such as Facebook, Twitter, or Pinterest). If you choose to take advantage of this functionality, people with access to your profile on the third-party platform will be able to see your post. Thus, you should have no expectation of privacy in those actions. Further, if you choose to link your profile on this Site with an account on a third-party social media platform, we may share the information in your profile with that third-party platform. We may also use platforms provided by companies such as Facebook and Google to offer you interest-based ads. In order to offer these ads, we may convert your email address into a unique value which can be matched by our partner company to a user on their platform. Although we do not provide any Personal Information to these platform vendors, they may gain insights about individuals who respond to the ads we serve.
Within the Wells Corporate Family. The owner and operator of this Site may share information collected through this Site with other companies in the Wells corporate structure. These affiliate companies are permitted to use your information for their own marketing purposes and in a manner otherwise consistent with this Policy.
In Aggregate or De-Identified Form. We may use information collected through this Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so we and they can better understand our user base. We may also share with third parties information about how particular individuals use this Site, but only on a de-identified basis (“Individualized Data”). Individualized Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively. We may provide basic demographic information (gender and age) in conjunction with providing Individualized Data. Third parties typically use this information for analytical purposes and to market their own products and services or the products and services of their clients.
With Other, Carefully Selected Business Partners. From time to time, we may share your information with selected third parties for their own marketing purposes. For example, we may partner with third parties to sponsor contests or other promotions, and we may share with these third parties the information you submit to us to participate in the contest or take advantage of the promotion. Before doing so, however, we may offer you the opportunity to “opt out” or “opt in,” as required by applicable law.
As Part of a Business Transfer. Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of this Site to another organization if we merge with or are acquired by another organization, or if we liquidate our assets. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.
To Comply With Laws and Protection of Our Rights and the Rights of Others. We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

12) YOUR RIGHTS AS A CALIFORNIA RESIDENT

Effective on January 1, 2020, the California Consumer Privacy Act (CCPA) provides consumers (California residents) with specific rights regarding their Personal Information. If you reside in California, you may exercise the following rights:

You have the right to request that we delete any of Personal Information data that we collected from you and retained, subject to certain Exceptions (as listed below). Once we receive and confirm your request, we will delete your Personal Information from our records unless an Exception applies.
We may deny your deletion request if retaining the information is necessary for us or our Provider(s):

A right to disclosure of the categories of Personal Information collected by us.
A right to disclosure of the specific pieces of Personal Information collected by us.
A right to deletion of Personal Information by us (subject to certain Exceptions outlined below).
A right to receive Personal Information in a format that will allow its transfer to third parties by you.
A right to opt-out of the “sale” of Personal Information, where a “sale” under the CCPA means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information to another business or a third party for monetary or other valuable consideration.”
A right to sue for security breaches of Personal Information.

Access to specific information and data portability rights
You have the right to request that we disclose to you your Personal Information we have collected about you over the past 12 months from the day of your request. Once we receive and confirm your request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business and commercial purposes for collecting or selling that Personal Information.
- The categories of third parties with whom we shared that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we “sold” or disclosed your Personal Information for a business purpose, up to two separate lists disclosing:
  - if we “sold” your Personal Information, “sales”, identifying the Personal Information categories that each category of recipient “purchased”; and
  - if we disclosed your Personal Information, disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion request rights
- to complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- to debug products to identify and repair errors that impair existing intended functionality;
- to exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- to comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- to engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- to enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- to comply with a legal obligation; or
- to make other internal and lawful uses of that information that are compatible with the context in which you provided it (each an “Exception” and collectively, “Exceptions”).
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: However, we may still offer you certain financial incentives that can result in different prices, rates or service quality levels as permitted by the CCPA. We do not at this time provide any such financial incentives.
- deny you goods or services;
- charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- provide you a different level or quality of goods or services; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Access, Data Portability and Deletion Rights
To exercise your rights described above, please submit a request to us by either:
Email: [email protected]
Phone: 1-800-331-0830

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
You may only make a request for access or data portability twice within a 12-month period. The request must: Making a request does not require you to create an account with us. Also, we will only use Personal Information provided in a request to verify the requestor’s identity or authority to make the request.
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Your Authorized Agent
You have the right to designate an authorized agent to make a request under the CCPA on your behalf.
Response Timing and Format

We will confirm that we received your request within ten (10) days and will respond within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response electronically or, at your option, by mail.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

13) CHILDREN UNDER THE AGE OF THIRTEEN

We are proud of this Site and we strive to ensure that it does not offend people of any age. However, this Site is not intended for children or minors under the age of thirteen years without the permission of a parent or guardian. If you believe that a child has submitted Personal Information on or through this Site without the consent and supervision of a parent or guardian, please contact us using the information provided below so that we can take appropriate action.

14) LINKS TO OTHER SITES

This Site may provide links to other websites operated by third parties, including in some cases our third-party vendors. Wells does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any Personal Information.

15) THIS POLICY MAY CHANGE

We are continually improving and adding to the features and functionality of this Site and the services we offer through this Site. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time, without prior notice, by posting the revised version of this Policy behind the link marked “Privacy Policy” at the bottom of each page of this Site. Your continued use of this Site after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy. However, we will honor the terms that were in effect when we gathered data from you.
For your convenience, whenever this Policy is changed, we will update the “effective date” at the top of this page. Be sure you check the effective date to see if this Policy has been revised since your last visit.
You may access the current version of this Policy at any time by clicking the link marked “Privacy Policy” at the bottom of each page of this Site.

16) CONTACT US

Our Privacy Policy describes: If you have any questions regarding this Privacy Policy, please contact us at:
Email: [email protected]
Phone: 1-800-331-0830