EXCELLENTIA FOODS LLC

1. Introduction and Scope

Excellentia Foods LLC (“Excellentia,” “Company,” “we,” “us,” or “our”) respects the privacy of the personal information it processes. This Privacy Policy (this “Policy”) explains how we collect, use, disclose, secure, and retain personal information in connection with our internal, web-based application that integrates with Intuit QuickBooks Online (the “Application”).

1.1 Internal use only.

The Application is a confidential business tool made available only to the Company's authorized employees and administrators (“Authorized Users”). It is not a public website or a consumer product, and it is not directed to the general public. This Policy is not a website-visitor or marketing privacy notice.

1.2 Who and what this covers.

This Policy applies to (a) personal information about Authorized Users that we process because they access and use the Application, and (b) personal information contained in the accounting and financial records that the Application accesses through its QuickBooks integration, which may include information about the Company's customers, vendors, and other third parties.

1.3 Relationship to the EULA.

This Policy supplements the Company's End-User License Agreement for the Application. Use of the Application is also governed by that agreement and by applicable Company policies.

2. Personal Information We Collect

2.1 We collect and process the following categories of personal information in connection with the Application:

• Identity and account information: your name, work email address, job title or role, user identifiers, and access credentials used to authenticate you to the Application.
• Usage and log data: information generated automatically when you use the Application, such as IP address, device and browser type, dates and times of access, pages and features used, queries run, and audit logs of actions taken within the Application.
• QuickBooks-sourced data: accounting and financial records the Application retrieves from or transmits to Intuit QuickBooks Online (“QuickBooks Data”), which may include the names, contact details, transaction histories, invoices, payment records, and financial information of the Company's customers, vendors, and other third parties.
• Communications: information you provide when you contact us about the Application, including the content of your messages.
• Sensitive information: Some information processed through the Application, such as financial account information, may be considered “sensitive personal information” under applicable law. We use and disclose such information only as necessary for the business purposes described in this Policy.

3. How We Collect Personal Information

3.1 We collect personal information: (a) directly from you, when you are granted access and when you use the Application; (b) automatically, through your use of the Application and its logging and security functions; and (c) from Intuit, through the Application's authorized connection to QuickBooks Online.

4. How We Use Personal Information

4.1 We use personal information for legitimate business purposes, including to:

• provide, operate, maintain, secure, and improve the Application;
• perform the Company's accounting, bookkeeping, financial, and other internal business functions through the QuickBooks integration;
• authenticate Authorized Users and manage access and permissions;
• monitor, audit, and log use of the Application for security, integrity, and compliance purposes;
• detect, investigate, prevent, and respond to security incidents, fraud, misuse, and unauthorized activity;
• comply with applicable laws, regulations, and our obligations to Intuit; and
• communicate with Authorized Users about the Application.

4.2 We do not use personal information processed through the Application for advertising, and we do not use advertising cookies or third-party advertising trackers in the Application.

5. How We Disclose Personal Information

5.1 We disclose personal information only as needed for the purposes described above, including to:

• Intuit: iin connection with the QuickBooks integration. Information exchanged with Intuit is also handled under Intuit's own terms and privacy statement, available at https://www.intuit.com/privacy/.
• Service providers: third parties that provide hosting, security, IT, and similar services on our behalf, bound by confidentiality and data-protection obligations.
• Within the Company: Authorized Users and personnel who have a legitimate need to know in order to perform their duties.
• Legal and compliance: courts, regulators, or other parties where required by law, to enforce our agreements, or to protect the rights, property, or safety of the Company, its personnel, or others.
• Business transfers: a successor or acquirer in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

5.2 No sale of personal information.

We do not sell personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under California law.

6. Intuit / QuickBooks Integration

6.1 Independent roles.

The Application connects to QuickBooks Online under Intuit's developer terms. With respect to personal information, the Company and Intuit each independently determine the purposes and means of their own processing and act as independent controllers, not joint controllers. Each party is responsible for its own compliance with applicable law.

6.2 Intuit's handling.

When data is exchanged with Intuit, Intuit may process and store it, including in countries other than where you are located, in accordance with Intuit's privacy statement. We encourage you to review it.

7. Monitoring and No Expectation of Privacy

7.1 The Application is a Company business system. To the extent permitted by applicable law, the Company may access, monitor, record, review, audit, and log all activity within the Application. Authorized Users should have no expectation of privacy in their use of the Application or in any data they place in it. This Section is consistent with, and supplements, the monitoring provisions of the EULA.

8. Data Security

8.1 We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, loss, or disclosure, including access controls, authentication, encryption in transit where appropriate, encryption at rest for data of comparable sensitivity, and logging. Authorized Users must comply with the Company's security requirements and must report any suspected security incident promptly as required by the EULA. In the event of a breach of the security of personal information, we will notify affected individuals and any other persons as and when required by applicable law, including California Civil Code section 1798.82. No system can be guaranteed to be completely secure.

9. Data Retention

9.1 We retain personal information for as long as necessary to operate the Application, to fulfill the purposes described in this Policy, and to comply with our legal, accounting, tax, and recordkeeping obligations. The criteria we use to determine retention periods include the category of personal information at issue, the purpose for which it is processed, the duration of the Authorized User's access and of the Company's relationship with the relevant customer or vendor, and the periods required by applicable accounting, tax, and recordkeeping laws and by our obligations to Intuit. On this basis, audit-log and security data, identity and credential data, and QuickBooks-sourced accounting records may be retained for different periods. When information is no longer needed, we securely delete or de-identify it, subject to any retention required by law or by our obligations to Intuit.

10. Your California Privacy Rights

10.1 Excellentia Foods LLC is based in California, and California residents, including employees and administrators, have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”). Subject to the CCPA's exceptions, you have the right to:

• know the categories and specific pieces of personal information we have collected about you, and how we use and disclose it;
• access a copy of your personal information;
• correct inaccurate personal information;
• request deletion of your personal information; and
• limit the use and disclosure of sensitive personal information to permitted business purposes.

10.2 Because we do not sell personal information or share it for cross-context behavioral advertising, no opt-out of sale or sharing is required. We will not discriminate against you for exercising your rights. We do not offer financial incentives, or price or service differences, in exchange for the collection, retention, or processing of personal information.

10.3 To exercise your rights, contact us using the details in Section 13. The email address in Section 13 is our designated method for submitting verifiable requests. You may submit a request yourself or through an authorized agent acting on your behalf; if you use an authorized agent, we may require the agent to provide proof of authorization and may require you to verify your own identity directly with us. We will verify your request and respond within the timeframes required by law. Some information must be retained where the law permits or requires, and certain records connected to QuickBooks Data may need to be addressed through Intuit.

10.4 Individuals who reside outside California, including customers, vendors, and other third parties whose information appears in QuickBooks Data, may have rights under the privacy laws of their own jurisdictions. If you believe such a law applies to your information, you may contact us using the details in Section 13, and we will respond as required by applicable law.

11. Children's Information

11.1 The Application is an internal tool for authorized personnel only. It is not intended for, or directed to, children, and we do not knowingly collect personal information from children under 13 through the Application. If you believe a child's information has been provided to us in error, please contact us so we can promptly delete it.

12. Cookies and Similar Technologies

12.1 The Application may use strictly necessary cookies and similar technologies to authenticate users, maintain sessions, and keep the Application secure. The Application does not use advertising or marketing cookies, and we do not permit third-party advertising networks to track activity within the Application.

13. Changes to This Policy; Contact

13.1 Changes.

We may update this Policy from time to time. We will post the updated Policy and, where appropriate, notify Authorized Users. The “Last Updated” date above indicates when this Policy was last revised. Continued use of the Application after an update constitutes acceptance of the revised Policy.

13.2 Contact.

If you have questions about this Policy or wish to exercise your privacy rights, contact us at: