FARMER'S FRIDGE

PRIVACY POLICY

Effective Date: July 2, 2018

Overview: Romaine Empire, Inc., d/b/a "Farmer's Fridge" ("Farmer's Fridge", "we", "us" and/or "our") knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. In this Privacy Policy we describe our data collection and usage practices with respect to information we collect from visitors to our web sites, users of our mobile applications on which we post a link to this Privacy Policy and users of our Fridge software through the use of touch screens available on all of our Fridges (collectively the "Services"). We hope this information increases your confidence in, and enhances your experience with, Farmer's Fridge. This Privacy Policy does not apply to data that we may collect through other means, including data that we may collect offline or via web or mobile sites on which we do not post this Privacy Policy. Each time that you use the Services, you signify that you agree to be bound by the Terms and Conditions and this Privacy Policy. If you do not agree to the terms of this Privacy Policy you must discontinue using the Services.

Information We Collect: When you interact with us through the Services, we may collect personally identifiable data ("Personal Data") and other information from you, as further described below:

Personal Data That You Provide Through the Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries or use certain Services. We may collect the following information from you in order to provide our Services:

- First and last name, or publicly posted name from a linked account;

- Email address;

- Phone number;

- Zip code or city and state that you are located in;

- Behavioral data such as usage statistics and purchase patterns (when linked with other personally identifiable data);

- Credit card information and/or other payment data;

- Your Farmer's Fridge Rewards account number;

- Demographic data (when linked with other personally identifiable data); and

- Other information that you voluntarily provide.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us through the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Farmer's Fridge and the authorized third parties referred to herein.

Passively Collected Data: When you interact with Farmer's Fridge through the Services, we and third parties that provide functionality on the Services, may engage, receive, collect and store certain types of information through automatic data collection tools including cookies, encrypted authentication tokens and similar technology. Such information, which is collected passively using various technologies, may include but is not limited to information about your device, referring/exit pages and URLs and number of clicks. Farmer's Fridge may store such information itself or such information may be included in databases owned and maintained by Farmer's Fridge affiliates, agents or third party service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Services, the number of visitors to each page of our Services, and the domain names of our visitors' Internet service providers. Such information that we collect will allow Farmer's Fridge to make educated decisions on how to provide better products and better services for our users. In operating the Services, we may use cookies. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, we may set a cookie on your browser that allows you to access our web sites without needing to remember and then enter a password more than once during a visit to our web sites.

Information from Third-party Analytics: We use or may use third-party analytics services, such as Google Analytics and Facebook Pixels, to evaluate your use of the Services, compile reports on activity occurring on and/or through the Services, collect demographic data, analyze performance metrics, and collect and evaluate other information related to the Site.

Google Analytics is a web analytics service provided by Google, Inc., ("Google"). Google Analytics places cookies on your computer, to help the website analyze how users use the Services. The information generated by the cookie about your use of the Services (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Services, compiling reports on Services activity and providing other services relating to Services activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using this Services, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html

Conversion Tracking or Custom Audience Pixel is a service provided by Facebook Inc. ("Facebook") that allows us to follow the actions of users after they are redirected by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data are saved and processed by Facebook. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes. For more information regarding Facebook Conversion Tracking, please visit Facebook's website, and pages that describe Facebook Conversion Tracking and Custom Audience Pixels, such as https://www.facebook.com/about/privacy and https://www.facebook.com/ads/website_custom_audiences, where you can also revoke permission for this service.

Do Not Track: We may (and we may allow third party service providers to) use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of our Services. Our Services currently do not respond to "Do Not Track" (DNT) signals and operate as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services and its customers, Farmer's Fridge often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Farmer's Fridge may share this aggregate data with its affiliates, agents and business partners for any purpose. This aggregate information does not identify you personally. Farmer's Fridge may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Location Information: Our Services may collect and use your location information (for example, by using the GPS on your mobile device) in connection with the operations of our business, including to provide and improve certain functionality of our Services. We may also use your location information in an aggregate way, as described above in the "Aggregated Personal Data" section.

Our Use of Your Personal Data and Other Information: Farmer's Fridge uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. For example, we will use your information to respond to your requests or questions. We may send you information about your account or our relationship with you. We may use your information to fulfill your orders, send you emails, send you marketing material and newsletters, provide push notifications to your device, send you text messages, improve the Services and analyze usage of our sites. If you elect to provide us with your mobile phone number, we will text you an invitation link to download the app or register with us. We will also use your mobile phone number to confirm your phone number and/or account at the time of sign up as well as sign in through a one-time password sent to you via a text message. We may also text you other information you agree to receive, including order confirmation or promotional material. If you elect to enable push notifications, we may send you notifications about the Services and various offers that we may make available from time to time. Farmer's Fridge may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and consumers, and to improve our products and services. Farmer's Fridge and its affiliates (its "Related Companies") may use this information to contact you or have third parties contact you in the future to tell you about services and products we believe will be of interest to you. If we do so, each such marketing communication sent to you will contain instructions permitting you to "opt-out" of receiving future marketing communications. Please note that if you elect to opt-out of the receipt of marketing-related emails, we will continue to contact you via email to respond to requests and provide our Services.

Our Disclosure of Your Personal Data and Other Information: There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might decide to sell or buy businesses or assets. In connection with any potential or actual corporate sale, merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution or similar event or transaction, Personal Data may be disclosed to third parties as it may be part of the assets potentially transferred or otherwise relevant to the transaction.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Third Parties: Farmer's Fridge, like many businesses, sometimes hires other companies to perform certain business-related functions, including to help us understand and improve the use of our Services. Examples of such functions include mailing information, verifying and augmenting Personal Data submitted by users, maintaining databases and processing payments. We may share any information we receive with vendors and service providers retained in connection with the operation of our business.

Legal Requirements: Farmer's Fridge may disclose your Personal Data if requested, subpoenaed and/or if we are required to do so by law, regulation, legal process, or by any court of competent jurisdiction or any inquiry or investigation by any governmental, official or regulatory body which is lawfully entitled to require any such disclosure, or otherwise in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Farmer's Fridge, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect Farmer's Fridge against potential legal liability.

Reports: In providing the Services, we may use aggregated Personal Data to generate certain analysis and reports ("Reports"), where such Reports may indirectly disclose information related to your Personal Data. Such Reports may be shared on certain Social Media Services (as defined below) without your explicit permission.

Apple Keychain: In providing the Services, we may utilize Apple Keychain to allow for the ability for you to automatically log into the Services. In using the Services, your user log in information is shared with Apple Keychain. For more information on how Apple Inc. uses this data, go to https://www.apple.com/privacy/.

Cooperative Databases: We may participate in cooperative data sharing databases. The participants of these databases provide certain Personal Data including customer names, mailing addresses and information about their customers' purchasing history to the database vendor which allows the database participants to segment and/or obtain access to potentially interested parties to which they may wish to target their own promotions.

Children: Farmer's Fridge does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal data to Farmer's Fridge, please contact us, and we will delete that information.

Links to Other Web Sites: This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Farmer's Fridge (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Farmer's Fridge endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Integrating Social Media Services: Through the Services, you may choose to access certain social media services, such as Facebook and Twitter ("Social Media Services"). When you elect to access and use the Social Media Services through those Third Party Sites you will be sharing your information (which will include personal information if you or other users elect to share such information) with those Social Media Services. As with other Third Party Sites, the information that you or others share with the Social Media Services will be governed by the privacy policies, and terms of service of the providers of such Social Media Services and not by Farmer's Fridge's policies and procedures. You may also have the option of posting your Services activities to Social Media Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Services); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Media Services you have enabled will be able to view, comment, and react to such activity.

Security: Farmer's Fridge takes commercially reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email or messages sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services. Farmer's Fridge cannot and does not guarantee that any Personal Data provided to Farmer's Fridge will not become public under any circumstances. Please keep this in mind when disclosing any Personal Data to Farmer's Fridge via the Internet.

Other Terms and Conditions: Your access to and use of the Services is subject to our Terms & Conditions available at http://www.farmersfridge.com/terms.

Changes to Our Privacy Policy: The Services and our business may change from time to time. As a result, at times it may be necessary for Farmer's Fridge to make changes to this Privacy Policy. Farmer's Fridge reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

International Users: If you are using the Services from outside of the United States, you expressly acknowledge and agree that your Personal Data and other information will be processed in the United States and potentially in other countries, where applicable privacy and data security laws may be less stringent than or otherwise different from the laws in effect in your country of residence. You expressly consent to the processing of your Personal Data and other information in accordance with this Privacy Policy.

Access to Information; Contact Us: To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take commercially reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services. Please also feel free to contact us if you have any questions about Farmer's Fridge's Privacy Policy or the information practices of the Services. You may contact us as follows: info@farmersfridge.com

Your California Privacy Rights: Applicable California privacy legislation permits visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request to access such information, please contact us as at: legal@farmersfridge.com. Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.