Privacy Policy

This Privacy Policy describes the privacy practices of Bartlett and Company, Inc. and Bartlett Milling Company L.P., (“Bartlett” or “we” or “us” or “our”) when you interact with www.bartlettco.com, www.bartlettandco.com, and the websites operated by or on behalf of Bartlett that link to this Privacy Policy (collectively, the “Websites”), when you use our services, and when you otherwise communicate with us online or offline (altogether referred to as our “Services”).

How We Collect and Use Your Personal Information

“Personal Information” is information that identifies, relates to, or could reasonably be linked with you or your household.

We collect and use your Personal Information in the following ways:

  1. When You Provide Information To Us: When you use our Services and provide us with your Personal Information, we may collect the following categories of Personal Information:
  • Identifiers and contact information, such as your first and last name, email address, company, mailing address, and phone number. If you create an account with us, we may keep a record of your account username. When you interact with us through our Websites, we may collect your IP address. We collect this information to communicate with you, for verifying your identity, and providing you with our Services.
  • Commercial information, such as products and services you have purchased from us. We collect this information to maintain customer records and perform analytics on customer relationships and trends for our own business purposes.
  • Transactional information, such as payment information. We collect this information to help process your orders and payments.
  • Other personally-identifiable information you choose to provide to us when you interact with us.

Our authorized Team Members may use this information to respond to your inquiries and comments, to fulfill and orders and requests, and to otherwise communicate with you including marketing of our Services.

  1. Automatically When You Use our Websites: We may collect the following categories of Personal Information when you use our Website and through tracking technologies. This information is sent to us automatically by your web browser and through certain tracking technologies:
    • Internet and other electronic network activity information, such as your browsing and search history, web browser information, information about your interaction with our Websites and when you visit other pages of the Internet, and IP address or other unique identifiers.

We use this information to monitor and maintain our Websites, perform analytics, streamline your interaction on our Websites, and find ways to improve our Websites. Please review the “Cookies and Tracking Technologies” section below to learn more about our use of cookies and how you can disable them.

How We Share Your Personal Information

We do not sell your Personal Information. We may, however, share your Personal Information in the course of our business, and in providing our services to you, in the following ways:

  • To our Service Providers: We may share your Personal Information with companies or individuals that we contract with in order to receive services (“Service Providers”). These services include, among other things, providing services to you on our behalf, creating or maintaining our databases and Websites, and performing analytic services for our Websites. We require our Service Providers to not use or disclose your Personal Information for any purpose other than for providing services to us.
  • To Business Partners and Affiliates: We may share your Personal Information with our business partners and affiliate companies. When we do so, we require these third parties to use your information in a manner consistent with the purposes for which it was originally collected (or to which you subsequently consented) and only as permitted under this Privacy Policy, and Country or Website-specific privacy statements and all applicable privacy and data protection laws.
  • To Comply With Legal Obligations: From time to time, we may be required to provide Personal Information to third parties in response to a court order, subpoena, government investigation, or as otherwise required by law or legal process.
    • We may also share your Personal Information with third parties, such as law enforcement agencies, when we, in good faith, believe that: (i) you or others are acting unlawfully; (ii) it is necessary or appropriate to satisfy any law, regulation or other governmental request; (iii) it is necessary to operate our business and Website properly; or (iv) to protect or defend our rights or the rights or well-being of others.
  • Due to Organizational Changes: We may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company (a “Reorganization Event”), transfer or assign your Personal Information to parties involved in the Reorganization Event. You acknowledge that such transfers may occur, and that any acquirer of our assets may continue to use your Personal Information as set forth in this Privacy Policy.
  • At Your Direction or with your Consent: If you instruct us to share your Personal Information with any third party, we will do so per your instruction and with your consent.

Cookies and Tracking Technologies

We may use “cookies” to keep, and sometimes track, information about you on our Websites. Cookies are small data files that are sent to your browser or related software from a Web server and stored on your computer’s hard drive. Cookies track where you travel on the Websites and what you look at. In doing so, a cookie may enable us to relate your use of the Websites to your Personal Information.

Most web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Refusing a cookie will generally not interfere with your use of the Websites. However, refusal of a cookie may, in some cases, preclude you from using or negatively impact the display or function of the Websites.

Third Party Analytics: We use Google Analytics to collect and process data about visitors’ use of our websites, for the purpose of optimizing website content and design. Information about how Google uses data collected from partners’ sites or apps, including Google’s use of “cookies” to identify and track website visitors’ IP addresses, is available at www.google.com/policies/privacy/partners/. To prevent Google Analytics from recognizing your IP address on return visits, you can disable cookies in your browser settings.

Do Not Track Signals: Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that the user does not want to have his or her online activity and behavior tracked. By sending a DNT signal, the browser can block the website from collecting certain information about the browser’s user. However, some online websites, including our Websites, are not configured to respond to DNT signals from web browsers. As such, we do not recognize or respond to DNT requests.

 Updating Your Personal Information

If you would like to update any Personal Information we hold about you, you can do so by contacting us at info@bartlettandco.com.

 Retention and Security

We retain your Personal Information to provide you with our services, including to fulfill your orders and requests and to communicate with you, and for use in marketing our services. We also retain your Personal Information as necessary to comply with our legal obligations, to resolve disputes and to enforce our agreements.

We have implemented reasonable safeguards designed to protect your information from loss, misuse, alteration or destruction. We also take reasonable steps designed to ensure that our third party partners and service providers agree to protect your Personal Information. That said, no method of transmission over the Internet, or method of electronic storage is 100 percent secure. Therefore, we cannot guarantee absolute security.

Links to Other Websites

Our Websites may contain links to other sites that are not owned or controlled by Bartlett. Except as described above regarding Service Providers, we do not control what information third parties track or collect. Your access to and use of these third-party websites is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information and privacy practices of these third parties and we encourage you to review the privacy practices of these third-party websites.

Children’s Privacy

Our Websites are not directed toward children under 16 years old and we do not knowingly collect any Personal Information from children under 16 years old. If we learn that a child under the age of 16 has submitted Personal Information to us, we will take all reasonable measures to delete the information as soon as possible and to not use such information for any purpose, except where necessary to protect the safety of the child or others as required or allowed by law. If you believe that a child under 16 years old has provided us with Personal Information, please contact us at info@bartlettandco.com.

California Residents

California residents may have certain rights under the California Consumer Privacy Act (“CCPA”) and the California Shine the Light law.

CCPA Disclosures: In general, within the preceding 12 months:

  • We have collected the categories of Personal Information identified above in the section entitled “How We Collect and Use Your Personal Information” directly from you and automatically when you use our Services.
  • We have disclosed and shared these categories of Personal Information for our business purposes as described in the section above entitled “How We Share Your Personal Information.”
  • We have not sold your Personal Information.

CCPA Privacy Rights: California residents may be entitled to the following privacy rights:

  • The right to know: You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of Personal Information we disclosed in the last 12 months; (v) the categories of third parties to whom we’ve disclosed your Personal Information in the last 12 months; and (vi) the purposes for collecting and sharing your Personal Information.
  • The right to request deletion: You have the right to request that we delete the Personal Information we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.
  • The right to opt-out of sale: You have the right to opt-out of our sale of your Personal Information. However, we do not sell your Personal Information.
  • The right to equal service: If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our Services.

You may exercise your right to know and right to request deletion twice a year free of charge. To exercise your right to know or right to request deletion please contact us at info@bartlettandco.com.

We will take steps to verify your identity before processing your request to know or delete. We will not fulfill your request unless you have provided sufficient information for us to verify you are the individual about whom we collected Personal Information. If you have an account with us, we may use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the Verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

California Shine the Light: We have not shared your Personal Information to third parties for their own direct marketing purposes.

Changes to Our Privacy Policy

We may occasionally update this Privacy Policy to reflect changes in our practice. When we post modifications or make material changes to this Privacy Policy, we will revise the “Last Updated” date and/or the “Effective Date” at the bottom of this web page.

We encourage you to periodically review this page for the latest information on our privacy practices.

For questions about this Privacy Policy or about our privacy practices in general, please contact (800) 888-6300 or info@bartlettandco.com.

Effective Date: 07/26/2021

Last Updated: 07/26/2021