The a2 Milk Company
PRIVACY POLICY

The a2 Milk Company (“a2”, “we”, “our”, or “us”) respects and is committed to protecting your privacy. This Privacy Policy lets you know how and for what purposes we are collecting, processing, and using your information. We pledge that we will take reasonable steps to ensure that your Personal Information (as defined herein) will only be used in ways that comply with this Privacy Policy.

This Privacy Policy applies to the Personal Information (as defined below) collected by us in relation to the recruitment of participants to test our a2 Platinum® infant formula (“the Purpose”), through our website located at (URL) (“the Website”). a2 will treat any offline collection, uses, and disclosures of your Personal Information consistently with our online privacy practices set forth in this Privacy Policy. This Privacy Policy is not applicable to any web page, mobile application, social media site, generic information, or Personal Information collected and/or owned by any entity other than us or for any data collection unrelated to the Purpose.

Types of Information Collected

a2 and any third party that we hire for the purpose of administering, operating, hosting, configuring, designing, maintaining and providing internal support for our Website may collect information when you visit the Website.

Personal Information: The types of information that we collect may include, among other things, the following categories of information (collectively, “Personal Information”):

contact information (e.g., your name, address, phone number, email address);
information relating to your baby; (e.g., birthdate, due date).

You are not required to provide any of this information, but if you choose not to provide certain information, we may not be able to provide you with the requested service. The information provided will be used as your profile (your “Profile”).

How Information Is Collected

We may collect Personal Information about you from the following sources:

the information that you send to us, including when you complete an online form;
information we receive from you through the Website and as a result of your use of our Website, such as when you create a Profile;
information we receive from your computer or mobile device when you use our Website;
information we receive from our affiliates, partners or service providers; and
information we receive from other sources, as permitted by applicable laws, rules and regulations.

You may be able to sign up to join our mailing list. If you sign up, we may from time-to-time send you emails and newsletters or other literature with information about one or more of our Websites and general information about us. You can unsubscribe from our newsletter at any time by the means set forth in that communication.

Use of Collected Personal Information

Personal Information collected by us may be used for the following primary purposes.

To provide you with information and communicate with you about the Purpose.
To personalize your experience on the Website.
To communicate with you and to inform you about a2’s products and services.
To help protect the integrity of the Website and our users.

When Personal Information Is Disclosed and Shared

We will disclose your Personal Information to our affiliates and third-party suppliers who are engaged in providing us services in relation to the Purpose, including Castor Research Inc., who host this Website, and the Virtual Research Group who are managing the a2 Platinum® study on behalf of a2. This will include sharing your Personal Information with the medical professionals who will determine your eligibility to participate in the a2 Platinum® study. We may disclose your Personal Information for any purpose disclosed by us when you provide the Personal Information. We may also disclosure your Personal Information with your permission or as directed by you.

We maintain reasonable safeguards to keep your Personal Information secure. When we provide Personal Information to our affiliates or third-party service providers as discussed in this Privacy Policy, we require that these parties agree to process such information in compliance with our Privacy Policy or in a manner that complies with applicable privacy laws. The use of your information by a trusted business partner may be subject to that party’s own privacy policy.

We may also disclose Personal Information when required by law or in the good-faith belief that such disclosure is necessary:

To comply with legal processes and applicable law.
To enforce this Privacy Policy.
To take precautions against liability and respond to any claim that any information provided by you violates the rights of a third party.
To assist government enforcement agencies.
To protect our rights, property, or the safety or the rights, property, or personal safety of our visitors and the public, which includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction, and, if required by law, disclosing information to U.S. federal and state governmental agencies.
To investigate potential unauthorized access or misuse of the Website.

We reserve the right to transfer your Personal Information, as well as any information about or obtained from you, in connection with the merger, sale or other disposition of all or part of our business and/or assets, or in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of our creditors. You expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above-described proceedings. We cannot and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the information that is disclosed to us.

Security

We maintain reasonable technical, administrative, organizational and physical security measures and controls to secure any Personal Information collected through the Website. However, there is always some risk that an unauthorized third-party could intercept an Internet transmission, or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting Personal Information over the Internet, especially any sensitive Personal Information. We cannot guarantee that unauthorized third parties will not gain access to your Personal Information; therefore, when submitting Personal Information to us through the Website, you must weigh both the benefits and the risks.

Information from Children

The Website is not intended or designed to attract children under the age of thirteen (13). You affirm that you are more than eighteen (18) years of age and are fully able and competent to enter your Personal Information in this Website in accordance with this Privacy Policy. In any case, by using the Website, you affirm that you are over the age of thirteen (13), as THE WEBSITE ARE NOT INTENDED FOR CHILDREN UNDER THIRTEEN (13) WHO ARE UNACCOMPANIED BY THEIR PARENT(S) OR LEGAL GUARDIAN(S). If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below, and we will work with you to address this issue.

Choices with Your Personal Information and Opting Out

Whether you submit any Personal Information to us is entirely up to you. You are under no obligation to provide any Personal Information to us. However, this information is essential for the provision and quality of some of the services that we offer to you, so we cannot provide you with certain services or provide you with access to certain features if you choose to withhold requested information.

You may choose to prevent us from disclosing or using your Personal Information under certain circumstances (“opt out”). You may opt out of any disclosure or use of your Personal Information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Policy. You also have the right to opt out of marketing communications from us by following the procedures set forth in an electronic communication from us, if applicable.

Please note that making such requests does not ensure complete or comprehensive removal of the Personal Information. For example, we may retain a certain level of Personal Information for our own internal records or to comply with applicable laws.

Access and Correction

Please contact us in the manner specified at the end of this Privacy Policy to access your Personal Information in our possession and correct inaccuracies of that information in our records. We ask individuals to identify themselves and the information requested to be accessed and amended before processing such requests, and we may decline to process requests in limited circumstances, as permitted by applicable laws, rules and regulations.

Your California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide certain personally identifiable information in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us (once per calendar year) information about the information that we shared (if any) with other businesses for their own direct marketing uses. If applicable, this information would include the categories of information and the names and addresses of those businesses with which we shared information for the immediately prior calendar year. To obtain this information, please send an email message to our service provider Virtual Research Group who will handle your request on our behalf at (email) with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response.

Under California Civil Code Section 1789.3, California residents who use the Website are entitled to the following consumer rights notice: The Website is owned and/or operated by Castor Research, Inc. on behalf of A2. Unless otherwise expressly stated, the Website is provided without charge. If you have a question or complaint regarding the services or products provided through the Website, please send an email to (email). You may also contact us by writing to us at 3800 Paramount Parkway, Suite 400, Morrisville, NC 27560 or by calling us at (phone number). California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at 916-445-1254 or 800-952-5210.

Under the definition of “selling” in the California Consumer Privacy Act, A2 does not sell your Personal Information.

“Do Not Track” Signals

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. Like many websites and online services, we currently do not alter our practices when we receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

Your Consent to This Privacy Policy

By accessing and using the Website, you consent to the collection and use of your information (including Personal Information) by us as specified above or as we otherwise see fit, in compliance with this Privacy Policy, unless you inform us otherwise by means of the procedure identified below.

If you have questions or comments or would like to access your Personal Information or opt out of certain sharing, please let us know by sending your comments or requests to our service provider Virtual Research Group, acting on behalf of a2:

Virtual Research Group

3800 Paramount Parkway, Suite 400,

Morrisville, NC 27560

Phone:

Email:

Accessing Our Sites Globally

This site is owned and operated by Castor Research, Inc., and if you are visiting this Website from a country outside the U.S., your communication with us will necessarily result in the transfer of information across international borders. This Website is not intended for the collection of Personal Information from outside the U.S. and a2 will not accept liability for any information entered by persons residing in other countries.

Changes to our Privacy Policy

We will only use Personal Information in the manner described in the Privacy Policy in effect when the information was collected from you or as authorized by you. However, and subject to any applicable consent requirements, or if required by law, we reserve the right to change the terms of this Privacy Policy at any time. Any changes to this Privacy Policy will be reflected on this page with a new effective date. We encourage you to review this Privacy Policy regularly for any changes. Any Personal Information collected upon your continued use of Website will be handled in accordance with the currently posted Privacy Policy.

Effective as of: 01JUN2023
Last updated: 01JUN2023