Privacy Policy

The S. Martinelli & Company

Effective Date: 9/14/2023

S. Martinelli & Company is committed to protecting your privacy. The information that you provide to S. Martinelli & Company (sometimes referred to as “we”, “us” or “our”) is utilized in order for us to (among other things) provide you with the highest level of customer service reflective of the quality of our brands.

This Privacy Policy (“Policy”) applies to our offline and online data collection practices, including when you visit our website at www.martinellis.com (referred herein as the “Site”), inquire about our products or services, make a purchase from us, subscribe to our mailing lists or when you engage with us via email or on social media.

This Policy is subject to our Terms and Conditions located at www.martinellis.com/terms-conditions. We may update this Policy from time to time, as specified in the “Changes to This Privacy Policy” section below.

California state law confers certain rights relating to personal information to its residents. If you are a California resident, please also see our California Consumer Privacy Section in this Policy located at: https://www.martinellis.com/privacy-policy#california

Your Consent

Please review this Policy periodically. You should read this entire Policy before submitting information, including personal information, to us in any form or using our Site. Whenever you submit personal information to us, you consent to the collection, use, disclosure, transfer, and storage of that information in accordance with this Policy.

All personal information may be used for the purposes stated in this Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form.

COLLECTION OF PERSONAL INFORMATION

We collect personal information using the following methods:
1) from you when you voluntarily provide it, including online when you visit our website, or when you interact with us in any other manner; and,
2) using automated technology, including when you visit our Site or interact with our electronic advertisements or communications; and
3) using third party sources including but not limited to service providers, entities providing data analysis and analytics, social media and social networking websites and other entities.
To see a complete list of what we collect, how we use this data, please see our Annex 1.

Personal Information

S. Martinelli & Company collects Personal Information, such as your email address, name, address, or telephone number based on your communications with us including purchase of products and submission of forms on the Site and communications via email, telephone call, and other electronic messages.

When you visit our website, we collect information about you through your browser, computer hardware and software. This information can include your IP address, device ID, browser type, domain names, access times and dates, number of clicks, pages viewed, one or more cookies (as described below) that may uniquely identify your browser, and referring website addresses. This information is used by S. Martinelli & Company for the improvement of our Site.

Sensitive Personal Information

S. Martinelli & Company collects sensitive personal information as set forth in Annex 1 Annex 1.

HOW WE USE YOUR PERSONAL INFORMATION

We use Personal Information of customers for a wide range of purposes, including:

  • to provide you with products and services or process requested transactions;
  • to respond to your requests and feedback;
  • to improve our products, business, and Site;
  • to follow up with you after you have communicated with us or submitted information to us;
  • to send promotional communications or offers (unless you have requested that we not send such communications);
  • for marketing, research, and legal purposes and other purposes;
  • to address your interests and concerns; and
  • as otherwise specified at the point of Personal Information collection.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

Service Providers and Contractors

We disclose Personal Information you provide to consultants, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s) such as vendors that help us communicate with you, vendors that host our website and data, security and fraud detection vendors.

Third Party Partners

We disclose Personal Information to third parties we work with who help us gather information from you and communicate with you including entities that provide sweepstakes/contests sponsorship, social media companies, and companies providing data analytics.

Legal Obligations

We may disclose Personal Information to outside parties (including, without limitation, governmental agencies) if required to do so by law, regulation, or court order; to respond to governmental and/or law enforcement requests; to identify, contact, or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense, or declaration in a case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel; or in connection with disciplinary actions/investigations.

Sale or Corporate Restructuring

We may disclose Personal Information to third parties in connection with the sale, assignment, or other transfer of the business of our website or the sale, assignment, merger, reorganization, or other transfer of our brand or company.

HOW WE USE “COOKIES” AND OTHER TECHNOLOGY

As you enter the Site, our server records and monitors your IP address and uses it to develop statistical analysis. These analyses assist us in refining and adapting the content and design of our site. The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users.

Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. A cookie is a small piece of information sent by a website that is saved on your hard drive by your computer’s browser. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags.

As you access or use our Site, we and/or third parties may collect information using cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy. Such automated technologies further help us to keep track of your interactions with our website and provide you with a more customized experience.

To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.

ANALYTICS DISCLAIMERS

We and/or third parties including service providers on our behalf use cookies, web beacons and other similar technology, to collect information for the purposes described in this Policy including analytics, monitoring performance, and improvement of our online services (traffic, errors, page load time, popular pages, etc.).

Google Analytics: We use Google Analytics to understand how our website, services, and products perform, and how you use them. We have already entered into a service provider addendum with Google. However, if you would like to take additional precautions to opt out of Google Analytics and Ads, you can opt out of Google Analytics by installing Google’s Opt Out browser add on: https://tools.google.com/dlpage/gaoptout and opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/.

This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies on third party websites or which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices.

Digital Advertising Alliance

You can also opt out from companies like Google, Meta, and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/. You can also opt out of participating companies from the Digital Advertising Alliance of Canada in Canada: http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe: http://www.youronlinechoices.eu/, or opt out using your mobile device settings.

Retention of Personal Information

We will retain your personal information (collected through offline and online methods) for as long as it is necessary for the purposes described in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. For more information regarding retention of personal information, see Annex 1.

Intended Audience of Websites

Our Site and social media accounts are not intended for people under the legal drinking age and as a result, we do not knowingly collect information from minors in the United States or elsewhere with or without the consent of their parents or guardians. If you are not 21 or older, you should not visit or use our Site or social media accounts.

External Links

We may make available third party applications through our Site and social media applications for your use. Links to such applications, any other websites included in this Site or links on our social media accounts operate with privacy policies beyond our control. Unless otherwise indicated, once you have left our Site or our social media account, all use of information you provide is governed by the privacy policy of the other website’s or social media account’s operators. We are not responsible for any transactions that occur between you and a third-party website or social media account.

Governing Law

This Policy and our privacy practices will be subject exclusively to the laws of the State of California, United States of America. We make no representation that this Policy and its practices comply with the laws of any other jurisdiction.

Contact Us

If you have any questions or concerns about this Policy, please contact us at privacy@martinellis.com.

CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD AND SHARED

Information Collected

In the preceding 12 months, we have collected the categories of personal information about California consumers as described in Annex 1 to this Notice. To review these categories click here: Annex 1.

Business-to-Business (“B2B”) Information

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent. See Annex 1 for more details.

Information Sold or Shared

We have not sold or shared any personal information for a business or commercial purpose in the preceding 12 months.

We have disclosed the following categories of personal information for a business or commercial purpose in the preceding 12 months:

  • Internet Activity

We do not knowingly sell the personal information of individuals under 16 years of age without affirmative authorization.

For details regarding the categories of third parties with whom we have shared, sold, or disclosed personal information, please see Annex 1.

Requests to Know

You have the right to request that we disclose personal information we collect about you.

To make a request for any of the information set forth above (a “Request to Know”), please submit a verifiable consumer request pursuant to the instructions below. You may make a Request to Know twice within a 12-month period. We will acknowledge your Request to Know within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Know must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold, or disclosed and must contain sufficient detail to allow us to properly understand, evaluate, and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.

You can make a Request to Know the personal information we have about you in the following ways:

  • Make your request by emailing us at privacy@martinellis.com;
  • You may also make a request by phone by contacting us at 1-800-622-1868.

Once we receive your Request to Know, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity.

RIGHT TO KNOW SENSITIVE PERSONAL INFORMATION COLLECTED

We collect and use Sensitive Personal Information as set forth in Annex 1.

We do not collect or process sensitive personal information for the purpose of inferring characteristics or for any purposes other than those set forth in Regulations Section 7027(m).

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

You have the right to request the deletion of your personal information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.

To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below. You may make a verifiable consumer Request to Delete twice within a 12-month period. We will acknowledge your Request to Delete within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Delete must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold, or disclosed and must contain sufficient detail to allow us to properly understand, evaluate, and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. Additionally, as permitted by law, if the information requested to be deleted is necessary for us to maintain, we will not be able to comply with your request. We will notify you if this is the case.

You can make a Request to Delete in the following ways:

  • Make your request by emailing us at privacy@martinellis.com;
  • You may also make a request by phone by contacting us at 1-800-622-1868.

Once we receive your initial request to delete and your separate confirmation to delete, we will need to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity.

We will retain correspondence, documents, and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.

This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices.

Cookies

As explained in our “Cookies and other technology” section , you can opt out of cookies using your browser.

Please Note:

  • Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
  • Opt-outs may be stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
  • We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our website, credit card processors, analytics processors. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
  • You may still receive ads from us that are not tailored to your interests.

ADDITIONAL OPTIONS TO OPT-OUT OF SALE OR SHARING

In addition to the above options to opt out of the sale or sharing of your information under the CCPA as described above, you have controls and choices with respect to the collection and use of your information by third-parties. These are summarized for you below. We do not control or maintain opt-out mechanisms for third-party companies and are not responsible for their operation.

Google Analytics: We use Google Analytics to understand how our website, services, and products perform, and how you use them. We have already entered into a service provider addendum with Google. However, if you would like to take additional precautions to opt out of Google Analytics and Ads, you can opt out of Google Analytics by installing Google’s Opt Out browser add on: https://tools.google.com/dlpage/gaoptout and opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/.

RIGHT TO CORRECT

You have the right to request that we rectify inaccurate information about you.

Requests to Correct

To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below. We will acknowledge your Request to Correct within 10 business days and we will attempt to respond substantively within 45-90 days.

You can make a Request to Correct in the following ways:

  • Make your request by emailing us at privacy@martinellis.com.
  • You may also make a request by phone by contacting us at 1-800-622-1868.

Once we receive your request to correct, we will need to verify that you are the person that is the subject of the request through the Verification Process.

We will review all information provided by you to us, to determine whether the information is inaccurate. We reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.

We will inform you of our decision to deny or grant your request.

We will retain correspondence, documents, and information related to any Request to Correct for 24 months as required by law.

RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING

We do not engage in automated decision making with respect to your personal information.

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.

NOTICE OF FINANCIAL INCENTIVE

From time to time, S. Martinelli & Company may provide financial incentives to consumers who elect to participate in these programs and, in connection with such programs, allow us to collect and retain certain personal information, such as Identifiers (e.g., your name, email address, or phone number), and Commercial Information (e.g., your purchase history). These incentives may result in differences in the prices of our products offered to consumers (e.g., discounts and other promotions). For example, the financial incentives we may provide include discounts based upon purchase activity or other periodic discounts for promotional purposes.

The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer.

Participation in any financial incentive program is entirely optional, and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions, or contact us using the contact information below.

Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty and repeat purchases.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for as long as it is necessary for the purposes set out in Annex 1 and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

AUTHORIZED AGENT INFORMATION

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

In order to allow an authorized agent to make a request on your behalf, please email us at privacy@martinellis.com to provide your written request and consent to an authorized agent.

When your authorized agent makes a request related to your personal information, we will require the agent to provide the above-written permission. We may also require that you verify your own identity directly with us at the time such a request is made.

California Do Not Track Notice

Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. In addition, we may allow third-parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above.

California Shine The Light Disclosure Information

Although we do not disclose any personal information to third-parties for their marketing purposes, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, email address, and the type of services provided to the customer, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (2) the names and addresses of all such third-parties. We will respond to such written requests within 30 days following receipt at the email or mailing address specified below under “Contact Us”. If we receive your request at a different email or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.

Changes to This Privacy Policy

This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.

CONTACT FOR MORE INFORMATION

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at privacy@martinellis.com.

ANNEX 1

Notice of Collection, Use, and Disclosure

See our full Privacy Policy here.

See California Privacy Rights here.

Category Examples Collected From Purposes Disclosed to Sold or Shared Retention Period
Personal Identifiers

Name, signature, mailing address, telephone number, email address, date of birth, and, credit card information.

You when you visit our Site (including your online activities on our Site), enter a promotion or competition conducted by us, engage with us on social media, or otherwise interact with us through posting content on our Site, or communicating with us in person, via phone or email or other methods.

To respond to and fulfill your requests; to verify your identity; to process your transactions when you have cashed out and to report your winnings for tax purposes;

To improve our products, services, Site, and social media;

To provide you with a customized user experience;

To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications);

To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account;

For marketing, research, legal, and other business purposes; and

To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.

Consultants, service providers, and contractors that we use to support our business and operations (e.g., hosting or operating our Site, data collection, reporting, ad response measurement, Site metrics and analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments, and providing fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services; 

Third-party payment processors, including in connection with transactions where we require credit or debit card account information such as credit or payment card account information (including card number, expiration date, and security code); 

Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics;

Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; 

An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of S. Martinelli & Company or its affiliates including any negotiation thereof; and

Third-party sponsors of contests, sweepstakes, discounts, and promotions that you enter into.

 

No

We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Commercial Information

Products or services purchased, obtained, considered, reviewed or other purchasing or consuming habits.

You when you visit our Site (including your online activities on our Site), enter a promotion or competition conducted by us, engage with us on social media, or otherwise interact with us through posting content on our Site, or communicating with us in person, via phone or email or other methods.

To respond to and fulfill your requests; to verify your identity; to process your transactions when you have cashed out and to report your winnings for tax purposes;

To improve our products, services, Site, and social media;

To provide you with a customized user experience;

To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications);

To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account;

For marketing, research, legal, and other business purposes; and

To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.

Consultants, service providers, and contractors that we use to support our business and operations (e.g., hosting or operating our Site, data collection, reporting, ad response measurement, Site metrics and analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments, and providing fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services; 

Third-party payment processors, including in connection with transactions where we require credit or debit card account information such as credit or payment card account information (including card number, expiration date, and security code); 

Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics;

Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; 

An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of S. Martinelli & Company or its affiliates including any negotiation thereof; and

Third-party sponsors of contests, sweepstakes, discounts, and promotions that you enter into.

 

No

 

We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Biometric Information

Photographs and videos

Your in-person visit to our premises including but not limited to our storefront or our manufacturing facilities

To maintain and preserve the safety of our guests, premises, property, and products;

Improve our premises and your customer experience; and

To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.

 

Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.

No

We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Internet/Network Activity

IP address, your device information, domain name, browsers you used to access our Site and services, webpages viewed, time spent on webpages, links clicks, transactions entered into and site-navigation patterns.

Your computer or mobile device, through your online activities and interactions with us, including, without limitation, your use of our services, your online activity on our Site, and on our social media channels or through our third-party sources.  

Third-party sources include third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.

Analyze and track usage of our services and products including our Site and social media accounts;

Determine the popularity of our products, Site, and services;

Better understand how you use our Site and services;

Improve our Site, services, and products;

Provide you with a customized user experience;

To send promotional communications or offers including invitations to events, taking surveys, and participating in promotions (unless you have requested that we not send such communications); 

For other marketing, research, legal, and other business purposes; and

To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.

 

Consultants, service providers, and contractors that we use to support our business and operations; 

Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; and

An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of S. Martinelli & Company or its affiliates including any negotiation thereof.

 

No

We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Business-to-Business (“B2B”) Information

Name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating the business relationship.

You, if you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.

For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.

We do not disclose B2B Information outside our business relationship without your consent.

No

We will retain your B2B Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.