McLANE COMPANY, INC.
PRIVACY NOTICE FOR INDIVIDUALS WHO VISIT McLANE WEBSITES
Effective Date: September 15, 2023
1. What is this document and why should you read it?
McLane Company, Inc. and its subsidiaries (collectively, “McLane”, “we”, “us”, or “our”) hold and process a wide range of information, some of which relates to you as an individual who visits our website, including www.mclaneco.com and other similar websites we operate (the “Site”). This Privacy Notice describes how we collect and process personal information about you when you visit the Site. It also sets out details of how to contact us if you have any questions regarding the personal information collected about you.
In this context, personal information generally means information from which you are identifiable or can be identified (e.g. your name, email address, and contact information), or other information about you that can be linked to you. In addition, processing means any activity relating to personal information, including, by way of example, collection, storage, use, consultation, disclosure, sharing and transmission.
In addition to visitors to the Site, this Privacy Notice applies to representatives of our corporate customers, inventory suppliers, and vendors (collectively, “Business Partners”) who conduct business with McLane or one of its subsidiaries or operating divisions, including but not limited to the McLane Foodservice division, Vantix Logistics, Inc., and Consumer Value Products.
This Privacy Notice does NOT apply to the following:
- Individuals who participate in loyalty and reward programs that are offered by our Business Partners and administered by McLane. You may access the privacy notice applicable to you as a loyalty or rewards program participant through the loyalty application.
- The McLane Xpress online platform. You may access the privacy notice applicable to McLane Xpress through the McLane Xpress online platform.
2. What types of personal information do we collect and where do we get it from?
For representatives of our Business Partners, as part of setting up your company’s account, we collect personal information like your name, corporate email address, physical address, phone number(s), and fax number; a tax ID number (which could be a Social Security Number); the name(s) and contact information of your chief executive officer(s) and other corporate contact personnel; images of your W-9 and various business licenses (e.g. to sell tobacco products); and banking information. We collect your Internet Protocol address when you visit the website, as well as location data such as city, state, and country. We may verify this information with publicly available information. If you do not provide information that is necessary for us to open your account, you may not be able to conduct business with us.
We will typically collect your personal information directly from you (for example, when you become a Business Partner, call us or send us an email, or register for our tradeshows) or through your interaction with our website. We may also collect personal information about you from third parties (that is, individuals and organizations that are not part of McLane). In addition, we may obtain it from some public sources, such as publicly available maps and lists (e.g. US-government lists of sanctioned entities).
The personal information about you that we collect includes information within the below categories. These categories also represent the categories of personal information that we have collected over the past 12 months. Note that the categories listed below are defined by California state law. Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category. Please note that, to the extent your tax ID number is your Social Security Number, we collect that information and disclose it for purposes of complying with tax and regulatory obligations.
|Category||Source||Purpose of Processing|
|Personal Identifiers. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.||This information is collected directly from you or from our service providers.||This information is necessary for us to open and maintain your account, call you or send you email, register you for our tradeshows, or process delivery of products or services to/from you. We also use it to send you notifications about your account, including billing statements, and to process/collect payments. We also use this information to advertise McLane products/services that might be of interest to you. We use this information for data analytics and compliance management.|
|Information About You. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||This information is collected directly from you or from our service providers.||This information is necessary for us to open your account, call you or send you email, register you for our tradeshows, process delivery of products or services to/from you. We also use it to send notifications about your account, including billing statements, and to process/collect payments. We also use this information to advertise McLane products/services that might be of interest to you. We use this information for data analytics.
We may also collect this information to verify your status as a business, to run a credit report, to ensure McLane is legally permitted to conduct financial transactions with you, and to verify your legal authority to do business and to sell certain regulated products (e.g. tobacco). We use this information for compliance management.
|Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||This information is collected directly from you.||This information is processed in order to service your account; to understand your preferences; to enable McLane and our service providers to generate analytics regarding your purchases from McLane (and our purchases from you); and to send you notifications, including billing statements, promotions, special offers or information about new products and/or services. We use this information for compliance management.|
|Usage Information. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.||Cookies and/or web beacons may be used to automatically collect a subset of this information from you when you visit our websites.||This information is used for marketing purposes, including offering you products/services that may be of interest to you.
It is also processed in order to help manage and administer your account, for data analytics, and technological development of our systems. It may be used to detect security incidents; protect against malicious, deceptive, fraudulent or illegal activity; and for compliance management.
|Recordings. Audio, electronic, visual, thermal, olfactory, or similar information.||This information is collected directly from you.||This information (e.g., recordings of customer service calls or data-related inquiries) is processed to respond to your queries and ensure the quality of our customer support operations. It may also be used to detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; and for compliance management.|
|Professional or Employment-Related Information, such as your employer and your job title.||This information is collected directly from you or through our service providers.||This information is necessary to open an account with us, call us or send us an email, or register for one of our tradeshows. We also use it to send notifications about your account, including billing statements. We use this information for compliance management.|
3. Who do we share personal information about you with, and why?
The broad classes of third parties to which we may transfer personal information about representatives of our Business Partners and visitors to the Site include:
- Third Party Service Providers. We disclose your information, including your personal information, to third party service providers for purposes of managing, providing, and improving the Site, as well as analyzing usage of the site. We also disclose your information, including your personal information, to third party service providers for the purpose of managing, providing, and improving the services we provide to our Business Partners. This may include marketing firms engaged by McLane to notify you of upcoming events or new products/services (note that such marketing firms may engage others to advertise products/services that may be of interest to you), and to provide analytics information to McLane, including location information; travel agencies engaged by McLane to make travel arrangements for you; contract compliance companies engaged to ensure payments received from you (or made to you by McLane) are consistent with the terms or our agreements with our Business Partners; data analytics providers; and consultants.
- Other Third Parties Where You Have Used or Directed Us to Disclose Your Personal Information to Them. You may use or direct us to disclose your personal information to third parties, which may include disclosure to payment processors for you to complete transactions and freight brokers, asset carriers, or shipping/delivery companies for you to receive the products you order from Mclane.
- Sharing For Protection of Us, You, and Others. We also transfer some personal information about you to government authorities (including tax authorities) where required by, or in order to comply with, applicable laws.
- Merger or Sale. If all or a portion of McLane, the site, or McLane’s assets are sold or transferred, personal information and other information collected about you may be treated as an asset and transferred in accordance with this Privacy Notice.
- Your Permission. We may also otherwise disclose your personal information with your permission.
We do not and do not intend to “sell” personal information about you, as defined under applicable privacy law. We also have not done so for the last 12 months. In addition, we do not share personal information for cross context behavioral advertising.
We will endeavor to ensure that all non-governmental third parties to whom we transfer personal information about you agree, as part of their contract with us, to treat personal information about you in accordance with applicable privacy laws.
When you visit our website(s), we give you the option to allow us to emplace certain “cookies” to operate our website(s), to make our website(s) more user-friendly, effective, and secure, and to offer you products tailored to your interests.
A cookie is a small piece of data sent from a website and stored in a file on your browser. A cookie is useful for having the browser remember specific information across several pages, across websites, or between visits to a website. We also use “pixels,” which are transparent image files sent from the website to your browser to help us record items like Internet Protocol address and time. For the purposes of this Privacy Notice, we refer to all these technologies as “cookies.”
Some cookies are essential to the proper functioning of our website. These are called “Strictly Necessary “cookies, and they will be set regardless of your consent. For non-essential cookies, including analytical cookies and targeting/marketing cookies we ask for your consent. You can modify your consent at any time by visiting the cookie preferences center available via the link titled “Cookie Settings” located in the footer of this page.
We use a tool called “Google Analytics” to collect information about use of our website. This tool uses persistent cookies to allow us to see behavior information relating to visitor age, gender and interests. It also collects device information, which includes a device’s Internet Protocol address and allows us to see device type, screen information, browser information, geographic location (city, state, and country), and the preferred language used to display our website. We may use this data to create remarketing lists. Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using Google’s Ad Settings. For information about opting out of Google Analytics using a browser add-on, please see this Google page.
You can also disable your browser from accepting cookies. Disabling cookies is unique to each browser and device you use. Disabling cookies on one device will restrict the ability to tie that device to other devices you use. If you disable marketing/targeted cookies, you will not receive advertisements tailored to your interests.
Do Not Track
We have implemented a cookie “door” to ensure your cookie preferences are honored, and as such, we do not sell or share personal information derived from cookies for cross context behavioral advertising. We nonetheless have tools in place to detect and honor requests made using the Global Privacy Control (“GPC”) signal as requests to opt-out of the sale or sharing of personal information to the extent required by applicable privacy law. If you wish to manage your cookie preferences directly with us, please visit the cookie preference center available via the link titled “Cookie Settings” located in the footer of this page, or make a request using one of the methods outlined in section 7 below.
5. Where do we keep personal information about you and for how long do we keep it?
We store personal information about you in physical files or on computer systems operated by or under the instruction of McLane, and/or in hard copy form at our premises or at off-site storage locations leased to McLane. We will maintain personal information about you for as long as necessary in connection with both our and your legal rights and obligations, and in accordance with our Records Retention Schedule. We will delete personal information about you in accordance with our Records Retention Schedule.
6. How do we keep personal information about you secure?
We have reasonable measures in place to prevent personal information from being accidentally lost, used, or accessed in an unauthorized way. We limit access to personal information to those who have a business need for such access. Those individuals who process personal information on our behalf may do so only in an authorized manner. They are also subject to a duty of confidentiality. We have policies in place that regulate how employees within McLane must handle information, including personal information. We limit access to our premises and to our computer networks, and we take reasonable steps to safeguard against unauthorized access to such premises and networks. We have procedures in place to manage any suspected information security breach and will notify you and any applicable regulator of an information security breach consistent with legal requirements.
7. What are your rights in relation to personal information about you and how can you exercise them?
Depending on where you live, your current jurisdiction and applicable privacy laws, and subject to any relevant restrictions/exemption, you may be entitled to all or some of the rights described below regarding your personal information, subject to certain conditions and limitations. Only those rights relevant in your jurisdiction will apply, and our inclusion of information about privacy laws does not imply that all privacy laws are applicable. We may, however, choose to offer these rights, even if we are not required to under applicable privacy law.
- Right to Know – You may be entitled to request that we disclose to you personal information we have collected about you, the categories of sources from which we collected the information, the purposes of collecting the information, the categories of third parties with whom we have shared the information, the categories of personal information that we have shared with third parties for a business purpose, the categories of information sold, and the categories of third parties information is sold to. In some instances, you may have the right to receive the information about you in a portable and readily usable format. Before providing any of this information, we must be able to verify your identity.
- Right to Opt-Out – You may have the right to opt-out of information sharing that constitutes “selling” or “sharing” personal information under applicable privacy law. Note however that we do not sell your Personal Information to or share your Personal Information with third parties for cross contextual advertising, nor do we intend to, as those terms are defined by applicable privacy law. We also have not done so for the last 12 months.
- Right to Limit – If we collect “sensitive personal information,” as that term is defined under applicable privacy law, you may have the right to direct us to limit our use of your sensitive personal information to certain purposes. Note however that we only use sensitive personal information for the purposes specified above.
- Right to Deletion – Subject to certain conditions, you may be entitled to request that we delete personal information about you. Before deleting personal information, we must be able to verify your identity. We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete certain personal information about you while continuing to provide you with certain products and services or where we are legally required to retain certain information.
- Right to Correction – You may be entitled to request that we correct inaccurate personal information. Before collecting personal information, we must be able to verify your identity. We will not correct personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information as-is by law.
Data solely retained for data backup purposes is principally excluded from these rights until it is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.
If you chose to exercise any of these rights, to the extent that they apply, privacy law prohibits us from discriminating against you on the basis of choosing to exercise your privacy rights.
Please note that under applicable privacy law, and for the protection of your personal information, we may be limited in what personal information we can disclose.
Before providing information you request in accordance with these rights, we must be able to verify your identity. In order to verify your identity, you will need to submit information about yourself, including your name, contact information, and, to the extent applicable, providing your account login credentials. We will match this information against information we have previously collected about you or provided to you to verify your identity and your request.
If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. We are not obligated to collect additional information in order to enable you to verify your identity. For deletion requests, you will be required to submit a verifiable request for deletion and then confirm separately that you want personal information about you deleted. If you would like to appoint an authorized agent to make a request on your behalf, you must provide the agent with written, signed permission to submit privacy right requests on your behalf. Alternatively, your authorized agent may provide evidence of having power of attorney or acting as a conservator for you. Note that we may require you to verify your identity with us directly before we provide any requested information to your authorized agent unless your authorized agent has power of attorney or acts as a conservator, in which case we will not contact you directly.
Information collected for purposes of verifying your request will only be used for verification.
You can submit requests to exercise these rights by calling us at 1-866-416-1384 to speak to a member of our team, sending an email to email@example.com, or clicking the link on the Site titled “Personal Information Request,” which will take you to a page explaining the process for submitting the available types of requests.
8. Children and minors
We do not knowingly collect personal information directly from individuals under 21 years of age, and we do not have actual knowledge of selling personal information of individuals under 21 years of age. Our services are not intended for individuals under 21 years of age. No one under 21 years of age should submit or post personal information through our services.
9. Changes to this Privacy Notice
We may change this Privacy Notice at any time, and in accordance with applicable law. We will post the revised Privacy Notice to our mclaneco.com website. The date this Privacy Notice was last revised will appear at the top of the page.
10. Where can you find out more?
You may call 1-866-416-1384 or send an email to firstname.lastname@example.org if you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or otherwise need to contact us.