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The Information We Collect

Welch's will not collect any personally-identifiable information about you through our website unless you provide it to us voluntarily. This policy applies to all information collected or submitted on the Welch's website. On some pages, you can make requests, register to receive materials or enter promotions. The types of personal information collected include: name, address, e-mail address, phone number, gender, permission to contact the person completing the registration, number of children in the household, if the registrant is a Welch's consumer or not, and general questions relating to product preferences or areas of interest on our website. We also collect the age of anyone who attempts to register this personally identifiable information on our site. We do this in order to fully comply with the rules and regulations under the Children's Online Privacy Protection Act to obtain parental consent for our visitors under the age of 13.

The Way We Use Information

In order to participate in any promotional activities (such as a sweepstakes) or request a coupon from Welch's or partake in certain other activities offered only within a members-only section within www.welchs.com, called "My Grapelink", a complete and approved registration record is required. Any area outside of the "My Grapelink" area of welchs.com is open to all visitors of the website.

We will use the information collected on the Welch's website to (a) allow registered users to access the "My Grapelink" section; (b) communicate with those registered users who have authorized Welch's to contact them to provide updates about our products and promotions; (c) develop new marketing and product ideas; and (d) notify sweepstakes winners of what they have won.

Information provided by registration or through a survey may be used internally by us to improve the design of our website, to increase our understanding of our consumers and their product preferences, and for other marketing and promotional purposes. For example, we may study responses relating to the perceptions or flavor preferences of our products by consumers. These learnings may then be used to shape future marketing decisions by us.

Welch's also collects aggregate, non-personally-identifiable information on users by recording the IP address from the computers of visitors to welchs.com. An IP address is a number that is assigned to your computer when you surf the Web. Web servers, or the computers that provide the web pages to your computer for you to view, automatically identify your computer by its IP address. When you use your computer to request to view a page from a server, your IP address is logged by that server. Welch's does not link IP addresses to anything personally identifiable. Your visit to welchs.com will be logged; however, you will remain anonymous to us. We track the number of people that view each page of our website to better understand which features are most popular and best meet the needs of our visitors.

Welch's will not sell or rent your personally identifiable information to anyone. Welch's will send personally identifiable information about you to other companies or people when:

• We have your consent to do so.
• We need to share the information in order to provide the product or service you have requested.
• We need to send the information to companies who work on behalf of Welch's to provide a product or service for you on our behalf. Examples include hosting and helping to run this Web site, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, and providing customer service. Unless we tell you differently, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us, unless they have your consent to do so.
• We need to respond to valid legal process. This includes a search warrant, subpoena, or court order, and any other instance when we believe we are required to do so by law. We may also make disclosures to protect your safety during emergencies if your physical safety is believed to be at risk, to protect the security or integrity of the Welch's Web site, or to take precautions against liability. We will take reasonable steps to limit the scope of these disclosures.

Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information (opt-out).

Welch's may share aggregated, non-personally identifiable information about our users with other companies for marketing and promotional purposes.

If you do not register with welchs.com, but only provide us with your e-mail address in connection with contacting Welch's by e-mail, we will use your e-mail addresses to answer your e-mail. If you authorize Welch's to contact you, we may use your e-mail address to send you notice of values and promotions, such as coupon offerings and sweepstakes.

Use of Cookies

Welch's website uses cookies to customize the visits of consumers to the "My Grapelink" section within the welchs.com website. Cookies are messages given to a Web browser (a software program that resides on your computer and allows you to surf the Web) by a Web server when the Web browser requests to "see" pages on a Web site. The browser stores the message from the server and sends it back to the server each time the browser requests to see a page from that server.

The use of cookies is an industry standard and you will find them at most websites. Most browsers are set to accept cookies. You always have the option to set the browser on your computer to refuse cookies. The main purpose of cookies is to identify users and prepare customized web pages for them to view. For example, you may receive a welcome message that includes your name instead of a generic welcome message. A cookie will also retrieve the information that was voluntarily provided by you to help improve your user experience or speed up your navigation on a website. You will need to enable the use of cookies to register on and navigate through the "My Grapelink" pages of welchs.com. You will not need to enable cookies to use any other part of welchs.com that does not require a personal registration record.

Our Commitment To Data Security

In an endeavor to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical and electronic procedures to safeguard and secure personal information we collect. We cannot guarantee the security of any information that you disclose online, and you do so at your own risk.

Welch's incorporates security measures to protect our data from unauthorized use. Firewalls are utilized to protect our servers and network from unauthorized users accessing and tampering with files and other information that we store.

Although we take the utmost care to protect your information, we cannot ensure the security of any information that you disclose online and transmit to us.

How You Can Access Or Correct Your Information

After registering with welchs.com, you will always have the option of editing the information you provided in your registration. To do this, visit the "My Grapelink" section of welchs.com, log in using your e-mail and password, and click on the "My Account" link on the "My Grapelink" page. You then may update your personal information or change your password. If you forget your password, go to the login page ("Welcome to Welch's Grapelink") of "My Grapelink", enter your e-mail address and click on the "Retrieve my Password" link. If you would like to unsubscribe from our database, please click here and type "unsubscribe" in your e-mail message.

OUR COMMITMENT TO CHILDREN'S PRIVACY

Welch's is committed to doing its part to protect the privacy of young children. Accordingly, and consistent with the Federal Children's Online Privacy Protection Act of 1998 (COPPA), Welch's will never knowingly collect personally identifiable information from anyone under the age of 13 without first obtaining verifiable consent from the child's parent or legal guardian.

The following sections of our Privacy Policy explain how Welch's collects and protects children's personal information, by describing:

• The personal information we collect from children under the age of 13 when they register on Welch's website and why we collect this information;
• How we may use the information we collect from children under the age of 13;
• How a parent may give us permission to obtain registration information from a child who is under the age of 13;
• How a parent may edit or delete the information submitted to us from a child who is under the age of 13;
• Who we may share this information with;
• Whether or not the information we request is necessary to register or participate in an activity on the Welch's website.

1. The Information We Collect from Children Under 13:

Welch's collects personal information from children under 13 so that they may participate as registered members of welchs.com and have access to the "My Grapelink" section of the Welch's website. "My Grapelink" allows registered users to participate in promotional activities such as contests and sweepstakes or request a coupon from Welch's.

We request the following information in order to register on Welch's website:

• E-mail address
• Password (selected by the child)
• Actual Name
• Address, including city, state and zip code
• Phone Number
• Gender
• Age (by range, not by specific date of birth)
• Permission to contact the person completing the registration to provide future announcements of values and promotions. (A grant of such permission to contact is not a prerequisite to participation in the "My Grapelink" section.)
• Number of children in the household (optional)
• If the registrant is a Welch's consumer or not (optional)
• General questions relating to product preferences or areas of interest on our website (optional)

If a registrant selects the "under 13" age range in that field, we will not use any information provided by that child unless and until we obtain parental consent to do so. We will request that the child provide us with their parent's or legal guardian's e-mail address, mailing address and phone number so we can request consent to retain the child's information. Until parental consent is received, for a child under 13, we will not use this information in any way. If Welch's does not receive verifiable parental consent within seven days of the child's attempt to register with welchs.com, we will permanently delete the child's personal information.

Welch's will not ask a child under age 13 to provide financially sensitive information such as credit card numbers.

2. How We May Use Information We Collect From Children Under Age 13:

We will use the information collected on the Welch's website to (a) allow registered users under 13 access to a members-only section within www.welchs.com, called "My Grapelink" and (b) communicate with our under 13 registered visitors via permission-based email messages, to provide updates about our products and promotions.

Unless the parent chooses to register as well with welchs.com, we will not use the parent's or guardian's e-mail address or mailing address for any purpose other than to communicate with the parent or guardian in order to obtain permission for their child to register and participate on the Welch's website. After the parent has provided consent for us to retain their child's information, we will keep the parent's information provided by the child on file to show that we have complied with our privacy protection policy, to send future requests for consent if necessary, and to ensure that only the child's parent can review the child's personal information. The parent will have an option to create their own registration record with us when they access their child's record to review, approve or delete it.

3. Permission Process - How A Parent May Give Consent to Collection of Information from a Child under Age 13:

As outlined above, all children under the age of 13 will be required to provide us with the name, mailing address, e-mail address, and phone number of their parent or legal guardian in order to seek to become officially registered on the Welch's website. Once the child has provided this information, we will send an e-mail to the parent explaining that the child is attempting to register on the site and explaining how the parent can provide consent or deny consent for the child's registration. This e-mail to the parent will provide the parent with a specific link, to access the child's information. Once the parent accesses the child's record, the parent will have the option to:

• Provide consent to retaining and using the child's information
• Edit the child's information and provide consent to retaining and using it
• Deny consent and delete the child's information

If a parent or guardian provides consent to collection and use of the child's information, an e-mail is sent to the parent, with a copy to the child, to confirm that Welch's has received parental consent and that the child now may participate as an officially registered member of the site. The child's registration to the Welch's website will be activated once the parent visits the website provides consent for Welch's to retain and use the child's information as outlined above.

In the event that the parent or guardian of the child who wishes to register to create a My Grapelink account does not have an e-mail account and does not have access to the Internet to create an e-mail account, an alternative means of parental consent will be provided. The child who is registering has the option of clicking on a link, located next to the e-mail field on the Parent/Guardian Consent Request page of My Grapelink. Once clicked upon, this link will provide instruction to the child to enter the following e-mail address into the e-mail field of the Parent/Guardian Consent Request page: customerservice@welchs.com. After this e-mail is entered, the child will complete the remainder of the page with their parent or guardian's name, address and phone number. After the child submits the information by clicking on the submit button at the bottom of the page, their record will be forwarded to customerservice@welchs.com, an internal Welch's e-mail account, established to receive such requests. Upon receipt, the e-mail will be printed out and mailed to the parent of the child who wishes to register. The e-mail printout, and two copies of the printout of the child's information that the child provided to Welch's, will accompany a letter to the parent. This letter will provide the same information as the e-mail letter that is sent to the parent upon the child's attempt to register. Welch's will require the parent to return one copy of the form containing their child's information with their signature, indicating their consent for Welch's to retain their child's online information. The parent may also edit the record and return one copy of the child's record, with their signature, to Welch's. The parent may also request that the record be deleted by indicating their wishes in writing on one copy of the child's record. If, within 21 days of the date that the child enters their information into Welch's Grapelink, a return letter is not received from the parent with instructions to approve (provide consent), edit (and provide consent) or delete the record of the child, the record will be automatically deleted by welchs.com. Parents who elect to return the letter of request for their consent for Welch's to retain their child's information must be addressed to:

Welch's Consumer Affairs
2 South Portage Street
Westfield, NY 14787-1492
Attn: www.welchs.com

Once Welch's has received consent from the parent of the child attempting to register, a letter confirming that consent to registration will be mailed to the parent, with a copy to the child.

4. How A Parent May Edit or Delete Their Child's Information or Revoke Consent:

The parent or guardian of a registered child, will always have the option at any time to view, change, or delete any of the information we have collected from their child. For security reasons, we will not give out any of the information that we have on file to enable access to a child's record. If a parent does not have the e-mail message that was sent to the parent containing the hypertext link (URL) to the child's personal information (the e-mail with a subject line "Request for Consent to Collect Child's Personal Information"), the parent may send an e-mail to: support@welchs.com and provide us with the child's name and the parent's e-mail address. The parent's e-mail address must match the parental e-mail address that the child provided to Welch's and to which Welch's e-mailed the request for parental consent. If the e-mail address you provide us in your request matches that provided by the child and from which we received parental consent, Welch's will then resend the original "Request for Consent to Collect Child's Personal Information" to the same e-mail address to which we originally sent it.

A parent or guardian of a child who does not have an e-mail account and has given their written consent to Welch's to retain the information provided by and collected about their child (as outlined in the section above: Permission Process – How a Parent May Give Consent to Collection of Information from a Child under Age 13) may wish to edit or delete this record in the future. The parent may do this by sending a written request at the address below, with explicit directions to edit or to delete their child's record. Welch's will mail to the parent a written confirmation of this edit or deletion, with a copy to the child.

5. Who We May Share this Information With:

Welch's has set forth the same guidelines regarding the way we use personal information to apply to the personally identifiable information of children under 13 who register with our site, as with registrants who are over the age of 13 and do not require parental consent to register with welchs.com:

Welch's will not sell or rent your personally identifiable information to anyone. Welch's will send personally identifiable information about you to other companies or people when:

• We have your consent to do so.
• We need to share the information in order to provide the product or service you have requested.
• We need to send the information to companies who work on behalf of Welch's to provide a product or service for you on our behalf. Examples include hosting and helping to run this Web site, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, and providing customer service. Unless we tell you differently, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us, unless they have your consent to do so.
• We need to respond to valid legal process. This includes a search warrant, subpoena, or court order, and any other instance when we believe we are required to do so by law. We may also make disclosures to protect your safety during emergencies if your physical safety is believed to be at risk, to protect the security or integrity of the Welch's Web site, or to take precautions against liability. We will take reasonable steps to limit the scope of these disclosures.

Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information (opt-out).

Welch's may share aggregated, non-personally identifiable information about our users with other companies for marketing and promotional purposes.

6. Whether or Not the Information We Request is Necessary to Register or Participate in an Activity on the Welch's Website:

Welch's cannot and will not condition a child's participation in an activity on this site on the child disclosing more personal information than is reasonably necessary to participate in the activity. Personal information sufficient to create a complete and approved registration record is required in order to participate in any promotional activities (such as sweepstakes) or, request a coupon from Welch's through the "My Grapelink" members-only section of welchs.com. All areas outside of the "My Grapelink" area of welchs.com are open to all visitors to the website.

Changes in Our Policy

Welch's reserves the right to change this Privacy Policy at our discretion. If we decide to change our Privacy Policy we will post those changes here. We encourage you to visit this section of our website frequently to be informed of any changes. If you provide consent to collection and use of personal information about your child and we make any material change in the type of information we collect or the way we use that information, we will notify you of those changes and obtain your permission before we request any additional personal information from your child. We will not change our policy to allow us to give personal information to a third party without first obtaining permission from our registered users and their parent or legal guardian if they are under age 13.

Your Consent to this Privacy Policy

By using this website, you agree to the parameters of this policy and agree to the terms stated herein by Welch's and Welch Foods Incorporated. If you do not agree with these terms, please do not use this site or submit any personal information.

How To Contact Us

If you have any questions or concerns about this Privacy Policy or our data collection practices, please contact us as follows:

Consumer Affairs
Welch Foods Inc., A Cooperative
2 South Portage Street
Westfield, NY 14787-1492
Phone: (800) 340-6870

email: askwelchs@welchs.com