Bumble Bee Foods, LLC ("Bumble Bee Foods") recognizes that many adults and children who visit our web site are concerned about how personal information they provide on-line is maintained and used by Bumble Bee Foods. To address these concerns and to demonstrate our firm commitment to privacy, especially for children who visit our sites, we have developed and implemented this privacy policy so you will know how Bumble Bee Foods gathers, and provides, information. Please review our privacy policy from time to time as we may update or change it periodically.

Gathering and Use of Information
Bumble Bee Foods collects personally identifiable information from visitors to our sites solely on a voluntary basis. Such personally identifiable information may include your name, postal address, e-mail address, company name and/or telephone numbers, et cetera (collectively referred to herein as "Personal Information"). We will never sell, transfer, or disclose any Personal Information we gather at our web sites to any third parties without your prior consent, except in cases when we believe in good faith that we have a legal obligation to disclose such Personal Information. We never require that this Personal Information be provided in order to gain access to our sites. We collect Personal Information primarily for the following reasons:

1. to e-mail consumers with updates and news
2. to notify winners of contests, games and sweepstakes, and to distribute prizes
3. to send out brochures, etc. via regular mail to subscribers
4. to distribute items that are part of "give aways" that you have registered for
5. for use in our online and off-line marketing and advertising campaigns. There may be times when we share aggregate information about our users (for example, the % of male and female visitors to our sites) with advertisers, business partners, sponsors, and other third parties in any effort to customize or enhance the content and advertising on our sites for our users.

We recognize there are unique issues raised about the protection of our children's privacy over the Internet. All children-directed Bumble Bee Foods web sites are designed to comply with the requirements of the Children's Online Privacy Protection Act (COPPA) and Children's Advertising Review Unit (CARU) guidelines for web sites gathering identifiable information from children (under age 13). Consistent with these requirements and guidelines, and provided that we have been given accurate information by the child when asked, we do NOT:

• collect personally identifiable off-line contact information without prior parental consent;
• distribute to third parties any personally identifiable information without prior parental consent;
• entice children by the prospect of a special game, prize or other activity, to divulge more information than is needed to participate in the activity;
• use or disclose on-line contact information without prior parental consent or parental notification, which will include an opportunity for the parent to prevent use of the information and participation in the activity. Without prior parental consent, on-line information will only be used to respond directly to the child's request and will not be used for other purposes without prior parental consent. We collect on-line contact information from children only in connection with on-line contests and sweepstakes; our policy with respect to using this information is provided below in the "Contests/Sweepstakes" section; or
• enable children to publicly post or otherwise distribute personally identifiable contact information without prior parental consent.

Parents can always ask to review any Personal Information about their child that may have been collected at one of our sites, have us delete any such Personal Information, and/or instruct us not to collect or use such Personal Information about their child in the future. To do so, simply contact us following the procedure outlined below in the "How To Contact Us" section.
As the new technology of the Internet evolves, and the COPPA requirements and CARU guidelines evolve as well, Bumble Bee Foods intends to comply with these requirements and guidelines in a manner and in as timely a fashion as is technologically feasible in order to protect our children and their privacy.

Contests/Sweepstakes
We periodically run contests and sweepstakes on our sites for which we ask users/participants to provide contact information (like their e-mail address). This information is used to contact the participant only when necessary in accordance with the rules of the contest or sweepstakes.

If a participant has indicated upon entering a contest or sweepstakes that he/she is under 13 years of age, the participant is instructed to enter the e-mail address of his/her parent or guardian. Further, for any game or contest where the screen names of the high scorers are posted, a user under 13 can only select a generic screen name from a list that has been developed in advance. This prevents the disclosure of any personally identifiable information.
When a participant under the age of 18 is selected as a prize-winner in a contest or sweepstakes, an e-mail is sent to the parent or guardian. This e-mail contains a form that requests the participant's real name and address and a parental permission form. For the participant to receive the prize, the parent or guardian must fill out and sign the form and then mail or fax it to the address or number indicated on the form.

Cookies/IP Addresses
Like many companies, Bumble Bee Foods may use "cookie" technology to track customer visits through our sites. Cookies are pieces of information that a web site transfers to an individual's hard drive for record-keeping purposes. They enhance the on-line experience by saving your preferences while you are visiting a particular site.

The cookies Bumble Bee Foods uses do not contain any personally identifying information and cannot profile your system or collect information from your hard drive. And although you may receive cookies from many different sites, each cookie can only be read by the Web server that originally issued it. You are not even identified by name or e-mail address, just by a unique string of numbers that we assign the first time you come to our site.

We use your IP address in two ways: to help diagnose problems with our server and to administer our web sites, and also to gather broad demographic information.

Polls & Surveys
Information gathered from polls and surveys are only for internal use of Bumble Bee Foods. If sample answers to polls or surveys are posted on the web site, then no identifiable Personal Information is ever included.

Choice/Opt-Out
Our sites will provide users the opportunity to opt out of receiving communications from us at the point where we request information about the visitor. Simply follow the procedure outlined at each site. Likewise, we will provide users with the opportunity to change any personal information previously provided, or to opt out of receiving future email communication from us.

How To Contact Us
If you have any questions about this Privacy Policy, the Legal Policy, the practices of this site, your dealings with this web site, or your Personal Information, please use our contact us form.

Final Note
Our goal at Bumble Bee Foods is to provide a safe Internet environment for you and your children. While children and young adults are encouraged to play our games and explore the web sites, we remind them often that their parents will be notified if they give us their e-mail address and their parent's written permission is required for them to be eligible to win prizes. We urge parents to spend time with their children on our web sites. Sit with them and share the experience. While Bumble Bee Foods does everything we can to ensure your child's privacy and safety, informed parents are the best protectors of their children.